A Lighter Supervisory Touch, But Not A Lower Bar: What The 2026 GSIB Regulatory Feedback May Signal For Resolution Planning

The Federal Reserve Board and FDIC’s (the Agencies) May 2026 feedback to the eight U.S. Global Systemically Important Banks (GSIBs) signals a potential meaningful shift in resolution planning supervision. While the Agencies reaffirmed their focus on operational capabilities developed through prior feedback letters, they stopped short of directing firms on how to further refine them. Instead, they placed responsibility on the GSIBs to critically examine their own capabilities and adapt them to changes in market conditions and each institution’s specific activities and risk. FDIC Chairman Hill’s remarks, consistent with OCC Comptroller Gould’s ongoing critiques, indicate there may be future changes to the framework for resolution plans under section 165(d) of the Dodd-Frank Act. However, the letters’ expectation of continued progress suggests there will not be a wholesale regulatory retreat. Against a backdrop of reduced supervisory resources, these developments may point to a move away from benchmarking to common GSIB practices and toward a more tailored, firm-specific approach grounded in management accountability and practical credibility.

Key points from the feedback letters are detailed below.

No Identified Deficiencies or Shortcomings

In a marked departure from past practice, the Agencies did not identify any new shortcomings or deficiencies in the 2025 plans. Historically, at least some GSIBs have received an identified shortcoming in each submission cycle. The Agencies also concluded that four firms that had a derivatives-related shortcoming identified in their 2023 plans had satisfactorily addressed those issues.

Limited Prescriptive Guidance for 2027 Plans and Findings of Consistent Implementation of Feedback in 2025 Targeted Plans

The feedback letters contained significantly less prescriptive direction regarding the content of the GSIBs’ next full resolution plans due in 2027. In prior cycles, the Agencies typically have provided detailed expectations for upcoming submissions. For example, the 2024 feedback letters included the following areas of emphasis for 2025 targeted plans:

• Development of assurance frameworks to provide governance and process around identifying, testing, and reporting on resolution capabilities;
• Enhanced analysis of regulatory consents and approvals, including those required outside the United States; and
• Expanded contingency strategies to raise capital and liquidity and downstream these resources to the material entities in the event of a shortfall in resolution.

The 2026 feedback letters indicate that GSIBs largely responded to this prior guidance in consistent ways:

• Assurance frameworks: Firms enhanced their ability to identify, test, and report on resolution capabilities, supported by strengthened governance, policies, and procedures, including around independent review and challenge functions and issue identification, aggregation, remediation, and escalation.
• Contingency strategies: Firms demonstrated their ability through exercises to deploy contingent actions, such as accelerating asset sales, delaying non-critical outflows, and accessing backup liquidity. Their forecasting capabilities were flexible and aligned with practices documented in secured support agreements and related methodologies.
• Non-U.S. necessary actions: Firms made what the Agencies described as “considerable effort” to identify potential impediments to executing preferred resolution strategies in foreign jurisdictions, along with mitigating actions.

Against this backdrop, for most of the GSIBs, the Agencies identified only two high-level areas for continued development in the 2027 plans:

• “Ongoing enhancement of the assurance framework and contingency strategies;” and
• Incorporation of changes in market conditions and firm-specific factors (including activities, risk profiles, and organizational structures) into resolution capabilities and strategies.

The Agencies also indicated that they expect to conduct additional capabilities testing in connection with their review of the 2027 plans.

Signals of a Broader Supervisory Shift from Benchmarking to Tailored Approaches

The restrained nature of this cycle’s feedback reflects the broader deregulatory trends in the second Trump administration, as well as the practical realities of staffing constraints at the Agencies. Consistent with the Federal Reserve Board’s recently updated Statement of Supervisory Operating Principles, the letters show an increased willingness by supervisors to rely on internal validation through the firm’s second and third lines of defense. The Agencies cited validation and confirmation by independent risk management and internal audit functions in finding four of the GSIBs had adequately addressed a derivatives-related shortcoming identified in 2023.

For GSIBs, the reduced level of prescriptive guidance may ease some of the burden associated with preparing 2027 plans. However, the absence of detailed regulatory direction shifts greater responsibility to firms to self-assess, on an institution-specific basis, where additional enhancements may be warranted. The Agencies’ expectation of reaction to market conditions also indicates a dynamic, ongoing approach will be needed, rather than one that is targeted around plan submission dates.

More Visible Divergence of Views Among FDIC and OCC Leadership

Despite the overall moderation in tone, the feedback letters did not go far enough for OCC Comptroller Gould, who abstained from the FDIC’s vote to approve them. Comptroller Gould has criticized planning components as complex compliance exercises that have become unmoored from statutory requirements and that lack real-world expected utility. The abstention brought into sharper focus a divergence in regulatory views that was first suggested by a January 2026 speech in which Comptroller Gould advocated for changes to the 165(d) resolution planning framework. In that speech, he called for, among other things, reducing the frequency of plan submissions and rescinding or putting out for public comment existing supervisory guidance. Until now, these positions had not drawn a public response or comments from the Agencies’ leadership on potential changes to the 165(d) regime.

Although he characterized the 2026 feedback as “relatively benign,” Comptroller Gould criticized the continued emphasis on assurance frameworks and contingency strategies, noting that these expectations stem from prior supervisory guidance rather than statutory requirements. He also raised concerns about the practical utility of detailed contingency planning, noting that an actual GSIB resolution would likely diverge significantly from any predefined plan. These views align with the OCC’s recent rescission of its recovery planning guidelines for national banks on the basis that these plans were duplicative and inherently speculative.

FDIC Chairman Hill appeared to address these concerns in his own remarks. He continued to focus primarily on insured depository institution resolution planning—an area where the FDIC is soon expected to propose rule amendments. However, Chairman Hill also signaled potential openness to a broader reassessment of the resolution planning framework. He indicated that the FDIC intends to “engage with the Federal Reserve Board on reconsidering elements of the Title I resolution planning process,” suggesting that more substantial changes could be under consideration.

Looking Forward to 2027 Plans

The 2026 feedback letters suggest a transitional moment for GSIB resolution planning. While firms will still need to refine and test their capabilities, the supervisory approach, for now, appears to be evolving toward greater flexibility and reliance on firm-driven assessments. At the same time, the Agencies’ emphasis on adapting to evolving market conditions and firm-specific risks heightens the importance of robust internal processes to identify change, assess its impact, and reflect it in resolution planning. As potential revisions to the section 165(d) framework are considered, institutions should prioritize iterative improvements to core capabilities while preparing for a potentially less prescriptive, more principles-based supervisory posture.

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