Fed, FDIC Clear JPM, BAC, and Citi Living Wills
Fazen Markets Editorial Desk
Collective editorial team · methodology
Fazen Markets Editorial Desk
Collective editorial team · methodology
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The Federal Reserve and the Federal Deposit Insurance Corporation announced on May 22, 2026, that they cleared the resolution plans for JPMorgan Chase, Bank of America, and Citigroup. The approval of these living wills means the regulators have no further feedback and will not require new submissions from these three major institutions. The news coincided with a positive trading session for bank stocks, with Bank of America shares trading at $51.80 as of 22:17 UTC today, a gain of 1.11% from the previous close. This regulatory clearance marks a significant shift from prior cycles and signals reduced immediate operational and capital risk for the banking giants.
This final approval concludes a multi-year process that began after the 2008 financial crisis with the Dodd-Frank Act. The last time regulators rejected a living will was in 2016, when the Fed and FDIC found flaws in the plans of five major banks, including JPMorgan and Bank of America. Those early rejections triggered strict capital distribution restrictions and forced costly restructuring within bank holding companies. The current macro backdrop features elevated interest rates, with the 10-year Treasury yield holding above 4.2%, pressuring net interest margins while providing tailwinds for certain lending operations.
The catalyst for this round of approvals is the banks' demonstrable progress in simplifying legal structures and enhancing operational resolvability. Regulators have focused on ensuring banks can fail without taxpayer bailouts or systemic disruption. The 2023 regional banking crisis underscored the continued importance of credible resolution frameworks, accelerating regulatory reviews. The Fed and FDIC are now satisfied that these three banks have sufficiently addressed prior deficiencies related to derivatives exposure, shared services, and cross-border coordination.
Bank of America's stock rose 1.11% to $51.80 on the news, within a daily trading range of $51.67 to $52.15. JPMorgan Chase, Citigroup, and Bank of America collectively represent approximately $2.5 trillion in total equity market capitalization. The 10-year U.S. Treasury yield, a key benchmark for bank profitability, was trading near 4.23% on the date of the announcement. The KBW Bank Index, a sector benchmark, has returned 7.5% year-to-date, underperforming the S&P 500's 12.1% gain over the same period.
Regulatory capital ratios for the three banks remain strong. JPMorgan reported a Common Equity Tier 1 capital ratio of 15.0% in its most recent quarter. Bank of America reported a CET1 ratio of 11.9%. Citigroup's ratio stood at 13.5%. All figures are well above the regulatory minimums. The table below shows the stock price reaction for the only one of the three banks with live data available at the time of the announcement.
| Ticker | Price | Daily Change |
|---|---|---|
| BAC | $51.80 | +1.11% |
The clearance directly benefits the cleared banks by removing a regulatory overhang that can constrain capital return strategies. This paves the way for more aggressive share buybacks and potential dividend increases, as capital buffers previously earmarked for resolution-related restructuring can be reallocated. Regional banks without the same systemic footprint, such as PNC Financial and U.S. Bancorp, may face relative investor outflows as capital seeks the reduced regulatory risk of the giants. Custody banks like State Street and asset managers like BlackRock could see indirect benefits from increased stability in their largest counterparties.
A key limitation is that a living will approval is not a permanent guarantee. The plans are reviewed on a two-year cycle, and future economic stress or changes in business models could trigger new feedback. The approval also does not shield the banks from other regulatory pressures, such as the Basel III Endgame capital reforms currently under debate. Positioning data shows institutional investors have been net buyers of large-cap bank shares over the past month, anticipating a dovish regulatory pivot and attractive valuations relative to the broader market.
Investors will monitor the Comprehensive Capital Analysis and Review results in late June 2026. The CCAR will reveal if the living will clearance translates into higher approved capital distributions from the Fed. The next Federal Open Market Committee meeting on June 18, 2026, will provide guidance on interest rate policy, a primary driver of bank earnings. Second-quarter earnings reports for the major banks, scheduled for mid-July 2026, will be scrutinized for commentary on the financial impact of this regulatory milestone.
Key technical levels for Bank of America to watch include the $53.20 resistance level, last tested in April 2026, and support near the 200-day moving average around $49.50. For the sector, the KBW Bank Index faces resistance at the 105 level. If the yield on the 10-year Treasury falls below 4.00%, it would pressure net interest income forecasts and could offset the positive regulatory sentiment, capping bank stock rallies.
A living will, formally called a resolution plan, is a detailed roadmap required by the Dodd-Frank Act for systemically important banks. It outlines how the institution could be rapidly and orderly dismantled in bankruptcy without taxpayer-funded bailouts or severe economic disruption. The plan must detail asset sales, legal entity wind-downs, and the continuity of critical operations. Regulators assess the feasibility of these plans every two years.
The clearance removes a major regulatory hurdle within the Fed's annual CCAR stress test process. Banks with deficient living wills historically faced automatic restrictions on capital distributions. With this hurdle cleared, JPMorgan, Bank of America, and Citigroup have a stronger case for requesting higher dividend payments and larger share repurchase programs from the Fed during the upcoming CCAR review, potentially returning more cash to shareholders.
The Fed and FDIC review living wills in cohorts based on bank size and complexity. JPMorgan, Bank of America, and Citigroup are in the most complex cohort, often reviewed first, with their plans setting a precedent. Other global systemically important banks, such as Wells Fargo and Goldman Sachs, which are in a different cohort, will receive feedback on their plans at a later date, though they are likely to seek similar final approvals.
Regulatory clearance of living wills for three major banks signals a mature post-crisis framework, reducing a capital overhang and shifting investor focus to fundamentals.
Disclaimer: This article is for informational purposes only and does not constitute investment advice. CFD trading carries high risk of capital loss.
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