FDIC and Financial Regulatory Reform - Title I and IDI Resolution Planning

Title I Resolution Planning

Section 165(d) of Title I of the Dodd-Frank Wall Street Reform and Consumer Protection Act (DFA), as amended by the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA), requires the largest Bank Holding Companies and other nonbank financial companies designated by the Financial Stability Oversight Council, to submit periodically  to the FDIC and the Federal Reserve Board resolution plans, alternatively referred to as living wills, Title I plans, or 165(d) plans.  

These companies must provide a plan for their rapid and orderly resolution under the U.S. Bankruptcy Code (or other ordinary insolvency regime) that demonstrates how their failure would avoid serious adverse effects on financial stability in the United States. The FDIC and the Federal Reserve Board review these resolution plans, and we may jointly make a determination of whether a plan is not credible or would not facilitate an orderly resolution of the firm under the U.S. Bankruptcy Code (or otherwise applicable ordinary insolvency regime). These Title I plans include both confidential and public sections.

IDI Resolution Planning

Section 360.10 of the FDIC’s Rules and Regulations —  “Resolution Plans Required for Insured Depository Institutions with $100 Billion or More in Total Assets; Informational Filings Required for Insured Depository Institutions with At Least $50 Billion but Less Than $100 Billion in Total Assets” (the IDI Resolution Planning Rule) -- supports resolution of large insured depository institutions (IDIs) under the Federal Deposit Insurance Act of 1950 as amended. The current rule, published on July 9, 2024, supersedes the original 2012 “Resolution Plans Required for Insured Depository Institutions with $50 Billion or More in Total Assets” and all prior guidance. The IDI resolution submissions include both confidential and public sections.

Public Sections of Resolution Submissions

The database below includes public sections of all Title I resolution plans and IDI resolution plans and informational filings submitted over the years, even those submitted by firms that are no longer subject to resolution submission requirements and those based on previous superseded rules or guidance.  The public sections available on the FDIC’s website have been provided exactly as submitted by the companies, without any modification.

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Resolution Submissions with Public Sections

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