FDIC Proposes Raising Resolution Submission Threshold to 100 Billion Dollars with Three Year Filing Cycle

Summary

The FDIC board on June 25, 2026, proposed revising resolution submission requirements for insured depository institutions, raising the coverage threshold from $50 billion to $100 billion in total assets with automatic indexing, moving all covered institutions to a three-year filing cycle, and streamlining content requirements to focus on information supporting cost-effective resolution. The board simultaneously exempted all currently covered institutions from October 2026 and 2027 filing requirements while the rulemaking proceeds.

Market Impact

Doubling the threshold to $100 billion releases the tier of regional banks between $50 billion and $100 billion in assets from resolution submission obligations entirely, while the three-year cycle and the immediate 2026-2027 filing exemption suspend a substantial recurring compliance workload for the remaining covered institutions. The indexing provision prevents the threshold from recapturing banks through balance sheet growth, making the relief durable rather than eroding with inflation.

Why It Matters

The proposal operationalizes the FDIC's stated shift from resolution planning as a compliance exercise toward resolution execution readiness -- the immediate filing exemption, granted before the rule is even final, signals the agency has already concluded the current submissions provide little value, consistent with Comptroller Gould's public position that resolution planning resources should be redirected to the FDIC's own execution capabilities.

Key Points

• The proposal raises the resolution submission asset threshold from $50 billion to $100 billion, with automatic future adjustments using an indexing methodology.
• All covered insured depository institutions would move to a three-year filing cycle.
• Filing requirements would be streamlined to focus on information most directly supporting cost-effective FDIC resolution readiness.
• The board approved an exemption from filing requirements in October 2026 and in 2027 for all institutions subject to the current rule.
• Comments will be accepted for 60 days after Federal Register publication.

Key Entities

Evidence

raise the asset threshold for determining whether an IDI is subject to the rule, from $50 billion to $100 billion and provide for automatic future adjustments using an indexing methodology.

Supports: The threshold doubling with indexing that permanently narrows covered institutions

the proposal would move all covered IDIs to a three-year cycle for filing submissions.

Supports: The reduced filing frequency for remaining covered institutions

the Board also approved today an exemption from filing requirements in October 2026 and in 2027 for all IDIs subject to the current rule.

Supports: The immediate relief: filing exemption granted before the rule is finalized