The Federal Deposit Insurance Corporation (FDIC) has formally proposed a series of regulatory changes that would significantly reduce compliance obligations for large insured depository institutions while lowering the banking industry’s annual deposit insurance assessment burden. On June 25, 2026, the FDIC Board of Directors approved two notices of proposed rulemaking: one overhauling the agency’s resolution planning rule for insured depository institutions and one amending its risk-based deposit insurance assessment framework. The proposals, previewed by Chairman Travis Hill in a June 9 speech, represent one of the agency’s most significant shifts in post-financial crisis resolution policy. They reflect a regulatory philosophy that emphasizes operational preparedness over extensive planning documentation and seek to recalibrate assessment rates in light of the Deposit Insurance Fund’s improved financial condition. FDIC staff estimate the assessment changes alone would reduce industry payments by roughly $4 billion per year.
For financial institutions, legal practitioners, and regulatory professionals, the proposals signal a meaningful change in how the FDIC intends to balance supervisory preparedness, compliance costs, and the long-term stability of the Deposit Insurance Fund (DIF).
What Is the FDIC Proposing to Change in Resolution Planning?
The centerpiece of the first proposal is a substantial revision to the FDIC’s insured depository institution (IDI) resolution planning requirements. Under the current rule, finalized in 2024, institutions with $100 billion or more in total assets must prepare comprehensive resolution plans describing how the institution could be resolved in an orderly manner if it were to fail, while institutions with between $50 billion and $100 billion in assets submit more limited informational filings. Full plans include detailed narratives addressing hypothetical failure scenarios, preferred resolution strategies, operational capabilities, governance, and obstacles to resolution.
The proposal would narrow the rule considerably. The applicability threshold would rise from $50 billion to $100 billion in total assets, indexed to inflation going forward, removing institutions in the $50 billion to $100 billion range from the rule entirely and reducing the number of covered banks from 48 to 32. All covered institutions would move to a three-year filing cycle, and the proposal would eliminate previously required public sections, interim supplements, capabilities testing, credibility assessments, and much of the hypothetical scenario analysis.
Chairman Hill has questioned whether lengthy narrative submissions continue to provide commensurate supervisory value. The revised rule would instead focus on operational information that would directly assist the agency in executing a resolution if a bank were to fail. Institutions would devote less effort to developing theoretical failure scenarios and more attention to maintaining accurate, readily accessible operational data that can be deployed quickly during an actual receivership.
This shift reflects lessons learned from recent bank failures and more than a decade of experience administering resolution planning requirements. Rather than requiring institutions to repeatedly update extensive narrative analyses, the FDIC intends to prioritize information that can facilitate a rapid transfer of deposits, preserve franchise value, and support an orderly resolution over a compressed time frame.
The New Resolution Readiness Adjustment
The most notable feature of the assessment proposal is a new “resolution readiness adjustment” within the FDIC’s deposit insurance assessment framework for larger institutions. Rather than treating resolution planning solely as a regulatory obligation, the proposal would create a financial incentive for banks that demonstrate tangible operational preparedness.
Banks subject to the FDIC’s large bank scorecard could qualify for a downward adjustment to their quarterly deposit insurance assessments by meeting specified operational benchmarks. Qualifying institutions would generally be expected to demonstrate an ability to populate a virtual data room on short notice or provide the FDIC temporary access to critical internal systems or third-party service providers, enabling regulators to quickly establish the technological infrastructure necessary during a resolution.
The adjustment reflects a broader view that operational readiness may contribute more to an orderly resolution than extensive written planning documents. By tying assessment reductions to measurable preparedness, the FDIC seeks to align supervisory objectives with economic incentives.
How Much Would Deposit Insurance Assessments Decrease?
Beyond the new readiness adjustment, the assessment proposal would reduce the industry’s overall deposit insurance burden by an estimated $4 billion annually.
The agency cites the improved financial condition of the Deposit Insurance Fund following the special assessment imposed after the 2023 regional banking failures and the continued rebuilding of the fund’s reserve ratio. For institutions evaluated under the small bank scorecard, assessment rates would decline by two basis points. Larger institutions would receive a smaller across-the-board reduction, with the opportunity to achieve comparable overall savings by opting in to the resolution readiness adjustment.
The proposal would also raise and index the $10 billion asset threshold that determines when institutions become subject to the large bank scorecard. Because the existing threshold has remained unchanged for many years despite inflation and industry growth, numerous regional institutions have become subject to the more complex assessment methodology despite having risk profiles substantially different from the largest banking organizations. Increasing and indexing the threshold would better align regulatory treatment with institutional size and complexity while reducing compliance burdens for many regional banks. Institutions near the threshold should note one wrinkle: some banks recategorized from large to small under the proposal could see their individual assessment rates change in unexpected ways, so the net effect warrants institution-specific analysis.
Changes to Part 370 and Qualified Financial Contract Requirements
Beyond the two formal proposals, the FDIC is evaluating revisions to several related operational requirements that have generated significant compliance costs.
Among the most notable is a possible replacement of the agency’s Part 370 deposit insurance determination rule with a streamlined version of Section 360.9. The revised framework would preserve standardized depositor recordkeeping requirements while eliminating the obligation for banks to maintain separate, independent insurance determination systems that many institutions have found expensive and operationally burdensome.
Similarly, the FDIC is considering narrowing the information required under its Qualified Financial Contracts rule to focus on data that institutions can realistically produce within the limited time available during a bank failure. The agency is also exploring greater reliance on transaction information already reported to existing regulatory data repositories rather than requiring duplicative reporting.
What These Proposals Mean for Banks
These proposals illustrate a broader effort by current FDIC leadership to recalibrate post-crisis regulation. Rather than eliminating resolution planning altogether, the agency appears intent on preserving requirements that directly improve resolution execution while reducing documentation that provides relatively limited incremental supervisory benefit.
For banking organizations, the proposals could produce meaningful reductions in ongoing compliance costs while rewarding investments in operational resilience and data accessibility. Legal and compliance professionals, however, should recognize that the shift is not deregulatory in the traditional sense. Institutions may devote fewer resources to drafting comprehensive narrative plans, but they may instead need to demonstrate sophisticated operational capabilities, robust data governance, and the technological infrastructure necessary to satisfy the proposed resolution readiness standards.
Both proposals are now open for public comment, and key implementation details, including the precise eligibility criteria for the resolution readiness adjustment and the final magnitude of assessment reductions, may evolve before any rules are adopted. Institutions with a stake in the outcome should consider submitting comments during the open period. The FDIC’s intent is clear: modernize the resolution framework by emphasizing practical readiness over extensive documentation while reducing the industry’s deposit insurance assessment burden as the Deposit Insurance Fund returns to a stronger financial position. For financial institutions and their advisers, these proposals warrant close attention as they may reshape both compliance programs and regulatory strategy for years to come.
If you have questions about how the FDIC’s proposed changes may affect your institution’s resolution planning obligations, assessment rates, or compliance strategy, or if you are considering submitting a comment during the rulemaking period, please contact KJK Partner Jessica Groza at 216.736.7214; JLG@kjk.com.