On December 31, the FDIC updated its resolution planning requirements for covered insured depository institutions (CIDIs), as it develops proposed amendments to the IDI rule. The FDIC stated that it plans to propose changes to the IDI rule for board consideration in 2026, expecting, at a minimum, to codify the content requirement exemptions and FAQs. The agency noted it also intends to propose additional changes based on lessons learned from reviewing submissions to the 2025 IDI rule, aiming to ensure that only the most critical information for executing a rapid, low-cost failed bank resolution under the FDI Act is required.
In anticipation of these revisions, the FDIC outlined 2026 submission requirements for CIDIs. CIDI subsidiaries of U.S. global systemically important banks, scheduled to file full resolution submissions by July 1, 2026, will instead submit interim supplements, reflecting their adoption of a single point of entry resolution strategy under the Title I Rule. The remaining group A CIDIs and group B CIDIs with submissions due by April 1 or July 1, 2026, will file as scheduled, subject to waivers for certain content. However, group B CIDIs with submissions due by October 1, 2026 — and any IDIs becoming CIDIs before a final rule is issued — would not be required to file until the rule is finalized, with the FDIC expecting to delay these submissions until amendments are completed.
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