Federal Regulators Clear 2025 Bank Resolution Plans Amid OCC Dissent
Washington, Friday, 29 May 2026.
On May 22, 2026, federal agencies approved major banks’ 2025 resolution plans. Crucially, OCC Comptroller Jonathan Gould abstained, condemning the binding regulatory review process as flawed and extralegal.
A Clean Bill of Health for Major Banks
The joint review, published by the Federal Reserve Board and the Federal Deposit Insurance Corporation (FDIC), evaluated the submissions of the eight largest and most complex domestic banking organizations, alongside 56 foreign banking entities [1]. Crucially for the stability of the United States economy, the agencies did not identify any new shortcomings or deficiencies in these July 2025 submissions [1][4].
These resolution plans, colloquially known as ‘living wills,’ are mandated strategies detailing how a bank would execute an orderly failure during material financial distress without triggering systemic disruption or requiring taxpayer funds [1][3]. The latest feedback highlights tangible progress in risk management; specifically, the agencies confirmed that derivatives-related weaknesses previously identified in the 2023 plans of Bank of America, Goldman Sachs, JPMorgan Chase, and Citigroup have been satisfactorily resolved [1].
The Roots of the ‘Extralegal’ Dissent
Despite the positive baseline assessments, the regulatory consensus fractured at the leadership level when Comptroller of the Currency Jonathan V. Gould, who took office on July 15, 2025, abstained from voting on the FDIC staff’s proposal regarding the U.S. global systemically important banks (GSIBs) [2][4]. In a sharply worded statement, Gould characterized the Section