On December 31, 2025, the FDIC issued an update outlining planned next steps in refining insured depository institution resolution planning requirements (IDI Rule) for covered insured depository institutions (CIDIs). The update builds on a series of policy adjustments, including the April 2025 modification, which shifted the focus of the resolution planning requirements toward capturing operational information most relevant to executing a resolution through a weekend sale or short‑term operations while marketing efforts are conducted. For more information, see our Alert, FDIC Modifies Approach to IDI Resolution Planning for Large Banks.
With the December 2025 update, the FDIC details several forthcoming changes to the IDI Rule. At minimum, it intends to propose for FDIC Board consideration, including:
- Codifying the content requirement exemptions and frequently asked questions (FAQs) introduced as part of the April 2025 modified approach.
- Additional revisions that reflect lessons learned from the FDIC’s review of 2025 IDI Rule submissions to ensure essential resolution information is provided and low-value requirements are removed.
- Continued evaluation of the interaction between the IDI Rule and the Title I Rule applicable to certain bank holding companies for potential adjustments to address overlap and improve alignment between the two frameworks.
The proposed changes aim to support the broader refocus of the resolution planning process and align with the agency’s evolving priorities.
As the FDIC readies formal rulemaking, it has outlined how it will handle 2026 resolution plan submissions across CIDI categories. For the 2026 submission cycle, the FDIC intends to modify or maintain filing expectations as follows:
- CIDI Subsidiaries of U.S. Global Systemically Important Banks (GSIBs): CIDI subsidiaries of U.S. GSIBs scheduled to file full resolution plans by July 1, 2026, will instead submit content equivalent to an interim supplement by that date.
- Remaining Group A CIDIs: Other Group A CIDIs must file as currently scheduled, subject to the FAQs and related content waivers. The FDIC also plans to grant additional waivers for valuation content that has shown limited value in reviewing the 2025 submissions.
- Group B CIDIs (April 1 or July 1 Filers): Group B CIDIs with full submissions due on or before April 1, 2026, or July 1, 2026, must file as currently scheduled, subject to the FAQs and related content waivers.
- Group B CIDIs (October 1 Filers): Group B CIDIs with full submissions or interim supplement filings due on or before October 1, 2026, and any IDIs that become CIDIs before the final rule is issued, will not be required to file until a final rule is issued.
In addition, the FDIC will conduct capabilities testing in 2026 to evaluate how quickly CIDIs can populate required information into the agency’s virtual data room (VDR). Prompted by lessons learned from the 2023 bank failures, these exercises are designed to ensure institutions can support rapid bidder due diligence during fast-moving bank failures. Testing will begin in early 2026 for CIDIs that submitted full plans in 2025, with testing for 2026 filers occurring in the months following their submission due date. For CIDI subsidiaries of U.S. GSIBs, this exercise is expected to be performed through the Title I planning process. The FDIC will provide notice approximately 30 days before testing begins.
How Forvis Mazars Can Help
The update underscores the FDIC’s commitment to broader policy trends that prioritize actionable, operationally focused information. As the industry awaits advancement of resolution planning rulemakings, CIDIs should anticipate evolving expectations. Further, institutions should carefully assess how the revised framework could potentially impact operations, including but not limited to, governance, resolution planning playbooks, and internal testing frameworks. Our team at Forvis Mazars is monitoring future resolution planning developments.
At Forvis Mazars, we support banks in conducting rigorous capabilities testing aligned to evaluating data integrity, assessing operational playbooks, validating core process execution, and ensuring critical functions can be sustained. With deep regulatory, risk, and operational expertise, we help institutions demonstrate readiness as the FDIC refines and modernizes its resolution planning framework.
If you have any questions or need assistance, please reach out to a professional at Forvis Mazars and let us be a resource for your institution.