Revalidating gaps, prioritizing enhancements, and preparing for the next Triennial Full Filer submission

The challenge

The client is a large international Foreign Banking Organization (FBO) with global operations and a growing US footprint. The bank’s strategic ambition to expand its US business brings it further into the scope of heightened US regulatory expectations, including the Federal Reserve and FDIC’s Final Resolution Planning Guidance for large US and non-US banks classified as “Triennial Full Filers.” As US assets, business lines, and interconnectedness grow, so does the standard the bank must meet on credible resolution capabilities.

In 2024, the bank conducted a comprehensive evaluation of its capabilities against the Federal Reserve and FDIC Final Resolution Planning Guidance for Triennial Full Filers. The results of that assessment were presented to senior management in early 2025 and confirmed a set of gaps that would need to be closed before the next targeted resolution plan submission, due July 1, 2028.

Entering 2026, the bank moved to expedite implementation of the required enhancements. Doing so meant revisiting the 2024 assessment against the current state of the organization, the evolving regulatory environment, and the bank’s own strategic plans — then converting the confirmed gaps into a prioritized, executable remediation program that could be delivered and demonstrated within roughly 2.5 years.

Several recent regulatory developments made this even more consequential:

• Stress testing transparency: The Federal Reserve approved new stress testing transparency proposals in October 2025, potentially affecting capital planning assumptions embedded in the resolution plan.
• Long-term debt requirements: Ongoing discussions on long-term debt requirements could affect the bank’s resolution capital structure.
• Post-March 2023 regulatory focus: Following the March 2023 bank failures, regulators intensified expectations for credible, operationally integrated resolution frameworks.
• FRB emphasis: The Federal Reserve has signaled a sharper focus on financial risk management, with a corresponding shift in the weight given to non-financial risks.

Our approach

We structured the 2026–2028 program in three phases, aligned to the regulatory timeline and to the practical reality that gaps identified in 2024 must be re-confirmed against 2026 conditions before large remediation investments are committed.

Phase 1 — Gap revalidation

Confirm which 2024 gaps remain material, in light of organizational, business, and regulatory change since the original assessment.

• Review 2024 assessment against current state: update organizational structure changes since 2025, review recent business model evolution and strategic plans for 2026–2027 that may affect the resolution planning program, and document changes since 2025.
• Regulatory environment scan: monitor for additional guidance or FAQs from agencies, review any regulatory feedback received on the last resolution plan submission, and track peer institution approaches and industry practices from October 2025 submissions.
• Stakeholder alignment: re-engage business lines on resolution capabilities, validate assumptions with Treasury, Risk, Finance, Legal, and Operations, confirm resource availability for enhancement implementation from each business unit and control function, and determine governance mechanism and accountability.
• Risk-based prioritization: reevaluate critical gaps that pose resolution obstacles, assess feasibility and additional resource requirements for all remediation programs, and evaluate interaction with other strategic and regulatory programs and priorities.

Phase 2 — Enhancement prioritization and detailed remediation plan

Convert the revalidated gap inventory into a prioritized, funded, and governed remediation program ready for execution.

• Development of the detailed remediation plan: conduct risk-based prioritization, develop remediation plan components, create integrated program management, and account for regulatory expectations and timelines.
• Implementation roadmap: define specific deliverables and milestones, and build in testing and validation phases ahead of the 2028 submission.
• Integration with other initiatives: align with broader risk management programs, coordinate with regulatory compliance projects, and leverage existing transformation initiatives to avoid duplication.
• Governance and accountability: establish a governance framework with clear oversight, and secure Board and executive alignment on scope, priorities, and pace.

Phase 3 — Implementation

Execute the developed plans against the July 1, 2028 submission target, giving the bank approximately 2.5 years from the start of 2026 to implement, test, and demonstrate all enhancements ahead of filing.

Deliverables and outcomes

• Prioritized gap inventory with scores, refreshed against the 2024 assessment.
• Detailed remediation plans for each confirmed gap.
• Budget and resource estimates for remediation.
• Established governance framework reviewed and approved by project sponsors and the Board.
• Program readiness to launch implementation on the late Q2–Q3 2026 timeline.

The program positions the bank to meet the July 1, 2028 targeted resolution plan submission with confidence.

• A revalidated, current-state view of gaps replaces a two-year-old assessment as the basis for investment decisions.
• A prioritized, governed remediation plan aligns Treasury, Risk, Finance, Legal, Operations, IT, and business lines around a single roadmap.
• Integration with existing risk, compliance, and transformation programs prevents duplicate build and competing priorities.
• A Board-approved governance framework provides ongoing oversight, accountability, and traceability through the 2.5-year implementation window.
• The bank is better positioned to absorb continued regulatory evolution — stress testing transparency, long-term debt requirements, and heightened supervisory expectations — without derailing the submission plan.

Key success factors

• Documentation: maintain comprehensive records of gap analysis and remediation efforts.
• Testing: build in robust testing of enhanced capabilities before the 2028 submission.
• Cross-functional collaboration: coordinate across Treasury, Risk, Legal, Operations, IT, and Business Lines.
• Regulatory engagement: sustain proactive dialogue with supervisors on enhancement approaches.
• Continuous monitoring: track regulatory developments that may affect resolution strategy through the delivery period.

Why this approach works for a growing US-facing FBO

For an international FBO scaling its US presence, resolution planning is no longer a periodic compliance exercise — it is an operational capability that must be visible in day-to-day processes, data, and governance. Structuring the program around revalidation before build, risk-based prioritization, and integration with existing initiatives lets the bank grow its US business while credibly demonstrating the resolution capabilities that heightened US regulatory expectations now require.