WASHINGTON—The Federal Deposit Insurance Corp. and Federal Reserve have released feedback letters tied to the latest “living will” resolution plans submitted by the nation’s largest banks, though Jonathan Gould abstained from the FDIC vote approving the feedback, arguing the broader resolution planning framework remains fundamentally flawed.
The feedback letters relate to July 2025 resolution plans filed under Section 165(d) of the Dodd-Frank Act, which requires the largest U.S. banking organizations to outline how they could be resolved in an orderly manner during a financial crisis. In a statement explaining his abstention, Gould, FDIC board member and Comptroller of the Currency, said he continues to believe there are “fundamental issues” with the current process and questioned both the value and legal underpinnings of aspects of the regime.
Gould noted the latest feedback letters were “relatively benign” compared with prior years, emphasizing that regulators did not identify any new “shortcomings” or deficiencies in the banks’ plans. However, he reiterated concerns first raised in a January speech in which he argued portions of the FDIC’s covered insured depository institution, or CIDI, planning requirements have evolved into a costly compliance exercise with limited practical value.
The debate highlights growing tensions inside banking agencies over the future of post-financial-crisis oversight frameworks. Gould has argued regulators should spend less time requiring banks to produce increasingly detailed failure-resolution plans and more time improving regulators’ own crisis-management capabilities, especially following the 2023 failures of Silicon Valley Bank and First Republic Bank. Industry observers said the latest developments suggest bank resolution planning requirements could face significant revisions under the Trump Administration’s broader push to ease supervisory burdens.