Stock Markets May 22, 2026 04:04 PM

U.S. Regulators Sign Off on Large Banks' 'Living Wills' After Prior Shortcomings Addressed

Federal Reserve and FDIC find plans from biggest U.S. and major foreign banks acceptable; earlier gaps tied to derivatives unwind resolved for four major firms

By Ajmal Hussain BAC GS JPM C

The Federal Reserve and the Federal Deposit Insurance Corporation have approved resolution plans - known as 'living wills' - submitted by the eight largest U.S. banks and 56 foreign banking organizations. The agencies reported no new deficiencies and said that earlier concerns raised in 2024 about the derivatives unwind plans of Bank of America, Goldman Sachs, JPMorgan Chase and Citigroup have been sufficiently remedied.

U.S. Regulators Sign Off on Large Banks' 'Living Wills' After Prior Shortcomings Addressed
BAC GS JPM C

Key Points

  • The Federal Reserve and FDIC found no deficiencies in the living wills of the eight largest U.S. banks and 56 foreign banking organizations.
  • Prior shortcomings identified in 2024 for Bank of America, Goldman Sachs, JPMorgan Chase and Citigroup - centering on how they would unwind derivatives portfolios - were deemed sufficiently addressed.
  • The determinations cover both domestic global banks and foreign banking entities subject to U.S. resolution plan requirements, with implications for regulatory oversight and market confidence in structured unwind plans.

WASHINGTON, May 22 - Two U.S. banking regulators have completed their review of resolution plans submitted by the country’s largest banks and major foreign banking organizations and did not identify any remaining deficiencies.

The Federal Reserve and the Federal Deposit Insurance Corporation reported that the so-called "living wills" filed by the eight largest U.S. banks and 56 foreign banking organizations met the agencies' standards in this review cycle. Regulators also announced that the specific shortcomings they had previously flagged in plans from Bank of America, Goldman Sachs, JPMorgan Chase and Citigroup have been addressed to the agencies' satisfaction.

Those four banks were singled out in 2024 after the agencies concluded their earlier filings did not adequately demonstrate how the firms could safely unwind derivatives portfolios in the event of bankruptcy. In the latest update, the Fed and FDIC indicated those gaps have been sufficiently remedied, and no additional failures were identified across the set of large domestic banks and the set of foreign banking organizations subject to review.

The regulatory findings encompass both U.S.-headquartered global banks and non-U.S. banks that operate in the United States and are required to submit resolution plans. By certifying the current submissions as free of identified deficiencies, the agencies signal that the stated mechanisms for a safe unwind in bankruptcy, including approaches for complex positions such as derivatives, satisfied the review criteria applied in this cycle.

The notice also included an unrelated investor-oriented segment discussing Citigroup's ticker symbol C. That segment described an AI-driven investment product called ProPicks AI, which evaluates Citigroup alongside many other companies using more than 100 financial metrics and highlighted past picks it noted as winners, including Super Micro Computer (+185%) and AppLovin (+157%). The segment offered readers an option to check whether Citigroup is included in any ProPicks AI strategies or to explore other opportunities.

The regulators' statement and the accompanying investor information were presented without identifying further corrective measures or additional unresolved items. Where earlier reviews had identified a narrow set of deficiencies related to derivatives unwind plans, the agencies now report those specific issues have been sufficiently addressed.


Context limitations: The agencies' announcement describes the outcome of the review and identifies that prior concerns were resolved, but it does not provide granular detail on the specific remedial steps the four banks took to remediate the earlier deficiencies.

Risks

  • The announcement does not disclose detailed remedial steps taken by the four banks to address the previously identified shortcomings, leaving limited public clarity on how derivatives unwind risks were operationally mitigated - impacts banking and derivatives markets.
  • The regulators' certification indicates no new deficiencies in this review, but future reviews could identify different or recurrent issues, affecting regulatory compliance burdens and the broader banking sector.
  • The investor promotional segment referencing Citigroup and an AI-driven picking tool presents potential perception and market-interest risks but does not alter the regulators' findings; market participants may interpret such material in varied ways.

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