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CONTENTS

CHAIRMAN’S MESSAGE ........................................................................................................2

MISSION, VISION, AND VALUES .............................................................................................3

Mission 3

Vision 3

Values 3

THE FDIC AND THE BANKING INDUSTRY: PERSPECTIVE AND OUTLOOK .....................................4

Introduction 4

The Impact of the Economy 5

Other Major Strategic Challenges 7

THE FDIC’S MAJOR PROGRAMS ...........................................................................................10

Insurance Program 11

Supervision Program 15

Supervision Program – Risk Management 17

Supervision Program – Consumer Protection and Economic Inclusion 21

Supervision Program – Resolution Planning 24

Receivership Management Program 27

Office of Inspector General ................................................................................................29

Appendices ......................................................................................................................30

Appendix A: The FDIC’s Strategic Planning Process 30

Appendix B: Enterprise Risk Management 32

Appendix C: The FDIC’s Use of Research, Data, and Analysis to Support Evidence-Based Policy 

Making and Program Management 33
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CHAIRMAN’S MESSAGE

The Federal Deposit Insurance Corporation’s 2022–2026 Strategic Plan will guide our efforts to carry 

out the agency’s mission, including maintaining stability and public confidence in the nation’s 

financial system by insuring deposits, examining and supervising financial institutions for safety and 

soundness and consumer protection, making large and complex financial institutions resolvable, and 

managing receiverships. This plan was approved by the Board of Directors on December 14, 2021. 

This strategic plan comes at a moment of inflection for the agency and for our country as we move 

into our “new normal” amidst the ever-evolving pandemic. Since FDIC insurance began in 1934, we 

have protected bank depositors and buttressed trust in our banking system as our nation faced 

challenges large and small.

In this 2022–2026 Strategic Plan, we outline our strategic goals and objectives, and the means and 

strategies we will use to achieve them. We also identify challenges associated with a post-pandemic 

economy in the years to come. In turn, this strategic plan will be implemented through annual 

performance plans with goals, indicators, and targets for each strategic objective. Our goals are 

ambitious and our success is crucial to individuals, households, businesses, and communities across 

the country. 

I want to thank the FDIC workforce for their continued dedication and resilience during the pandemic. 

Their hard work has allowed the agency to achieve its mission during these unprecedented times and 

to move forward on important new initiatives, including encouraging innovation, supporting 

community and mission-driven banks, and fostering a banking system that can meet the needs of 

business and consumers across our nation. 

Jelena McWilliams

Chairman
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MISSION, VISION, AND VALUES

Mission

The Federal Deposit Insurance Corporation 

(FDIC) is an independent agency created by the 

Congress to maintain stability and public 

confidence in the nation’s financial system by:

• Insuring deposits,

• Examining and supervising financial 

institutions for safety and soundness and 

consumer protection,

• Making large, complex financial 

institutions resolvable, and

• Managing receiverships.

Vision

The FDIC is a recognized leader in promoting 

sound public policies; addressing risks in the 

nation’s financial system; and carrying out its 

insurance, supervisory, consumer protection, 

resolution planning, and receivership 

management responsibilities.

Values

The FDIC and its employees have a tradition of 

distinguished public service. Six core values 

guide us in accomplishing our mission:

• Integrity. We adhere to the highest 

ethical and professional standards.

• Competence. We are a highly skilled, 

dedicated, and diverse workforce that 

is empowered to achieve outstanding 

results.

• Teamwork. We communicate and 

collaborate effectively with one 

another and with other regulatory 

agencies.

• Effectiveness. We respond quickly 

and successfully to risks in insured 

depository institutions and the 

financial system.

• Accountability. We are accountable 

to each other and to our stakeholders 

to operate in a financially responsible 

and operationally effective manner.

• Fairness. We respect individual 

viewpoints and treat one another and 

our stakeholders with impartiality, 

dignity, and trust.
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THE FDIC AND THE BANKING INDUSTRY: 

PERSPECTIVE AND OUTLOOK

Introduction

Congress created the FDIC in the Banking Act 

of 1933 to maintain stability and public 

confidence in the nation’s banking system. 

The statute provided a federal government 

guarantee of deposits in U.S. depository 

institutions so that depositors’ funds, within 

certain limits, would be safe and available to 

them in the event of a failure of an insured 

depository institution (IDI). The FDIC acts as 

receiver for IDIs that fail, and has resolution 

planning responsibilities for large, complex 

financial institutions. In addition to its role as 

insurer, the FDIC is the primary federal 

regulator of federally insured state-chartered 

banks that are not members of the Federal 

Reserve System. 

The FDIC carries out its mission through three 

major programs: insurance, supervision, and 

receivership management.

The Insurance Program encompasses the 

activities undertaken by the FDIC to administer 

the Deposit Insurance Fund (DIF), which is 

funded through assessments on IDIs as well as 

investment income, to resolve failed IDIs in the 

manner least costly to the DIF, and to provide 

depositors with timely access to their insured 

funds when an IDI fails.

The Supervision Program encompasses the 

activities undertaken by the FDIC to promote 

safe and sound operations and compliance 

with fair lending, consumer protection, and 

other applicable statutes and regulations by 

IDIs for which the FDIC is the primary federal 

regulator (in cooperation with state banking 

agencies). The FDIC also has backup 

supervisory responsibility for other IDIs for 

which the Board of Governors of the Federal 

Reserve System (FRB) and the Office of the 

Comptroller of the Currency (OCC) are the 

primary federal regulators.

PRIMARY FEDERAL 

REGULATOR

NUMBER OF 

INSTITUTIONS

TOTAL ASSETS (DOLLARS IN 

MILLIONS)

FDIC 3,171 $4,206,831

OCC 1,019 $15,082,333

FRB 724 $3,962,496

TOTAL 4,914 $23,251,660

Source: Quarterly Banking Profile. Data as of 9/30/2021.
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The FDIC is responsible for monitoring and 

assessing risks posed by, and planning for the 

resolution of, large, complex financial 

institutions (LCFIs) under authority derived 

from the Federal Deposit Insurance Act (FDI 

Act) and the Wall Street Reform and Consumer 

Protection Act (Dodd-Frank Act). As part of this 

work, the FDIC and the FRB have joint 

responsibility for reviewing resolution plans 

submitted by large bank holding companies 

and designated nonbank financial companies 

that demonstrate how they would be resolved 

in a rapid and orderly manner in the event of 

financial distress; and, under specified 

circumstances, administer the orderly 

liquidations of covered financial companies.

The Receivership Management Program 

encompasses activities undertaken by the 

FDIC, in its capacity as receiver, to maximize 

net recoveries to the creditors of receiverships.

Over the next four years, the FDIC will face 

numerous issues and challenges in each of 

these major programs associated with a postpandemic economy and related impacts to the 

financial services industry and consumer and 

business preferences. Some of the major 

issues and challenges are addressed in more 

detail below.

The Impact of the Economy

The performance of the economy directly 

affects the performance of individual financial 

institutions and the overall banking industry. 

Interest rates, inflation, unemployment, the 

business cycle, and shocks to specific sectors 

like agriculture, energy, housing, or 

commercial real estate all influence lending 

and funding strategies of IDIs. Economic and 

financial conditions abroad also have an 

impact on the U.S. economy and on the 

performance of banks.

As of third quarter 2021, the United States had 

regained the output lost from a deep recession 

that occurred in early 2020 caused by the 

Coronavirus Disease 2019 (COVID-19)

pandemic. Significant government stimulus 

for individuals and small businesses in 2020 

and 2021 helped support the economy, with 

most programs ending in third quarter 2021. 

Restrictions on economic activity eased and 

vaccination rates improved in 2021, which 

further contributed to stronger economic 

growth. Consumer spending remains strong. 

In aggregate, household balance sheets 

remained resilient and household wealth 

increased from rising home prices and stock 

market valuations. Business investment 

continued to recover and returned to prepandemic levels. However, business and 

economic activity were constrained by supply 

chain bottlenecks and shortages. These factors 

along with stronger consumer demand 

contributed to higher inflation in 2021. Overall, 

the economic outlook is for continued 

moderate growth, although uncertainty 

remains, as lingering supply chain issues feed 

into inflationary pressures and businesses and 

individuals adjust to changes as the pandemic 

evolves. 

Banks generally entered this period of 

disruption with strong asset quality and capital 
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and liquidity ratios, and were able to serve as a 

source of strength for the economy, 

individuals and small businesses throughout 

the global health epidemic.

Although loan balances contracted between 

the first quarter 2020 and the first quarter 

2021, the first such annual contraction since 

the third quarter 2011, financial institutions 

supported the economic recovery with lending 

through the first and second rounds of the 

Paycheck Protection Program and by working 

with impacted borrowers. The decline in loan 

volume and the persistent low interest rate 

environment caused contraction in the 

average net interest margin, which set three 

record lows over the past year. In contrast, 

deposits grew at unprecedented rates over the 

same period. In third quarter 2021, banks 

reported modest improvement in the average 

net interest margin supported by loan growth.

Despite these challenges, the banking industry 

remains resilient. Strong capital and liquidity 

levels support lending and help protect against 

potential losses. Industry-wide profitability (as 

measured by return on assets) remains strong. 

The number of problem institutions has fallen 

dramatically from the post-crisis high and is at 

its lowest level since 2008.

While the banking industry continues to 

perform well, the interest-rate environment 

and economic uncertainty continue to pose 

challenges for many institutions. 

Overall, the industry must manage interestrate risk, liquidity risk, and credit risk carefully 

to remain on a long-term, sustainable growth 

path.

The United States experienced the sharpest 

economic contraction in the post-WWII period 

in early 2020 with the sudden onset of the 

COVID-19 pandemic, and the unemployment 

rate reached double-digit levels. The resulting 

recession ended a period of subdued but 

sustained economic growth since the last 

recession ended in mid-2009. The subsequent 

labor market weakness, business closures, and 

lower interest rates all posed challenges to 

banks. Conditions improved considerably in 

2021, helped by expansive fiscal and monetary 

policy implemented in 2020 and 2021 to 

support businesses and consumers, the rollout

of vaccines, and reduced pandemic-related 

restrictions in economic activity. However, 

this economic environment has posed several 

key challenges for the banking industry. The 

economic outlook remains uncertain and 

depends on the path of the pandemic as well 

as the outlook for fiscal and monetary policy in 

their effects on economic activity and interest 

rates.

As of third quarter 2021, banks generally 

maintained strong asset quality, capital, and 

liquidity positions. Annual loan growth slowed 

in recent quarters; however, remains positive. 

Industry-wide profitability (as measured by the 

return on assets ratio) has been trending up, 

and the majority of banks report year-overyear growth in quarterly net income. The 

growth in net income is due to reductions in 
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provisions for credit losses. The number of 

problem institutions remains near the lowest 

level since 2008.

Other Major Strategic 

Challenges

In addition to the challenges posed by the 

economy, the FDIC expects to face other 

challenges that will shape its priorities over the 

next four years.

Future of Community Banking. The FDIC is 

the primary federal regulator for most 

community banks, which make up 91 percent 

of FDIC-insured bank and thrift charters (up 

from 87 percent in 1984); hold a majority of 

deposits in rural and “micropolitan” counties 

(those with populations up to 50,000 people), 

including more than 600 U.S. counties where 

community banks hold 100 percent of all bank 

deposits; and account for 39 percent of the 

industry’s small loans to farms and 

businesses.1

 Despite their long-term resilience 

and continuing importance as a source of 

credit to the vital small business sector, 

community banks continue to face 

competitive challenges from non-community 

banks and non-bank financial technology 

competitors.

1 Based on the definition of community banks in the FDIC Community Banking Study, 2012.

Regional Banks

Regional banks have continued to grow in 

number, assets, and complexity. FDIC 

supervises a growing percentage of the 

regional bank universe, as community banks 

continue to merge and grow organically. FDIC 

also has both insurance risk monitoring and 

back-up supervisory responsibilities for the 

remaining regional banks. Similar to 

community bankers, regional banks face 

competitive challenges from large, complex 

financial institutions and non-bank technology 

competitors. An increasing number of regional 

banks have less traditional business models, 

including for example monoline operations, 

concentrated lending or funding operations, 

nationwide lending platforms, and other niche 

activities. 

Large, Complex Financial Institutions

(LCFIs). Although the FDIC is not the primary 

federal regulator for most large, complex IDIs, 

it has both insurance and back-up supervisory 

responsibilities for those institutions and acts 

as receiver for those that fail. The assets 

within the banking industry are concentrated 

today in a small number of large, complex 

banks that have highly diverse business 

strategies and complex legal and business 

structures that necessitate ongoing 

monitoring of their risks. These risks are 

intertwined among both their insured and 
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uninsured subsidiaries, and the largest and 

most complex of these companies have 

significant international operations and 

interdependent counterparty relationships 

with one another that increase their 

complexity and risk.

Innovation, Information Technology, and 

Cybersecurity. Some banks have responded 

to the previously discussed economic 

challenges by investing in innovative 

technologies to boost profitability through 

reduced overhead expenses. Others are 

offering new services to their customers by 

partnering with technology companies on the 

front lines of innovation, or by adopting new 

technologies themselves. Cybersecurity 

threats continue to pose risks to banks, 

businesses, consumers, financial markets, and 

the FDIC. Some institutions are leveraging 

innovative technology solutions to enhance 

their resilience to a cybersecurity attack. In 

addition to addressing cybersecurity threats 

internally, the FDIC works collaboratively with 

other federal and state agencies to help ensure 

that FDIC-insured institutions also take 

appropriate steps to address this risk. 

Economic Inclusion. Based on a 2019 FDIC 

survey, 5.4 percent of U.S. households did not 

have an account at an IDI.

2

The FDIC recognizes that public confidence in

the banking system is strengthened when 

2 2015 National Survey of Unbanked and Underbanked Households, October 2016, October 2020. The survey found that 5.4 

percent of U.S. households (7.1 million households) did not have a bank or credit union account in 2019.

households effectively use the mainstream 

banking system to deposit funds securely, 

conduct basic financial transactions, 

accumulate savings, and access credit on safe 

and affordable terms. The FDIC will continue 

to promote greater economic inclusion and 

financial well-being by helping more 

underserved households and communities 

benefit from the products and services of FDICinsured institutions. The FDIC’s #GetBanked 

initiative encourages consumers to start a 

banking relationship. The FDIC also 

communicates directly with banks to promote 

the importance of offering safe and affordable 

bank accounts, such as checkless checking 

accounts. FDIC’s Money Smart program 

provides people with practical knowledge, 

skills-building opportunities, and resources to 

manage finances with confidence. 

This work requires engagement with banks of 

all sizes, as well as with local governments and 

community leaders. FDIC facilitates business 

and partnership opportunities and promotes 

financial education. By helping to connect 

banks and communities in new ways, and 

increasing awareness and use of affordable 

banking services, the FDIC strengthens the 

banking system and communities nationwide.
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Workforce Management and 

Development. The FDIC depends upon the 

talents and skills of its employees to 

accomplish its mission. Much of the FDIC’s 

current workforce is eligible to retire over the 

next decade, creating an opportunity to 

transform both the workforce and the manner 

in which the FDIC meets its mission. To 

address this workplace reality, the FDIC will 

continue to enhance its data collection and 

analysis efforts to inform development and 

implementation of succession management 

strategies over the next several years. These 

efforts will include specific recruitment and 

development strategies to support a high 

performing workforce that reflects the 

communities we serve by optimizing 

experiences throughout an employee’s 

career. These actions will ensure that the FDIC 

workplace is inclusive, free from unlawful 

discrimination, and provides equal 

opportunity and accessibility in all its 

employment and business activities. The FDIC 

has issued a 2021-2023 Diversity, Equity, and 

Inclusion Strategic Plan that guides its 

efforts. Strategies also include the 

modernization of learning and development 

by transforming the FDIC’s use of virtual 

learning, enhancing learning technology, and 

modernizing the training center.
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THE FDIC’S MAJOR PROGRAMS

The FDIC has three major program areas or 

lines of business. The agency’s strategic goals 

for each of these programs are presented in 

the diagram below.

Program Areas Strategic Goals

Insurance

FDIC-insured deposits are protected from loss 

without recourse to taxpayer funding.

Supervision

FDIC-insured institutions are safe and sound.

FDIC-supervised institutions comply with federal 

consumer protection laws, including fair lending 

laws, and the Community Reinvestment Act 

(CRA).

Large, complex financial institutions are 

resolvable in an orderly manner.

Receivership Management Resolutions are orderly and receiverships are 

managed effectively.
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Insurance Program

Program Description

Deposit insurance is a fundamental 

component of the FDIC’s role in maintaining 

stability and public confidence in the U.S. 

financial system. By promoting industry and 

consumer awareness of deposit insurance, the 

FDIC protects deposits at banks and savings

associations of all sizes. When IDIs fail, the 

FDIC ensures that customers have timely 

access to their insured deposits and other 

services. The basic limit of federal deposit 

insurance coverage is currently $250,000 per 

depositor. To keep pace with the evolving 

banking industry and maintain its readiness to 

protect insured depositors, the FDIC prepares 

and maintains contingency plans to promptly 

address a variety of types of IDI failures and 

conducts large scale simulations to test its 

plans.

The DIF must remain viable so that adequate 

funds are available to protect insured deposits 

in the event of an institution’s failure. The 

FDIC maintains a sufficient DIF balance by 

collecting risk-based insurance premiums from 

IDIs and through prudent fund investment 

strategies. The FDIC continually evaluates the 

adequacy of the DIF. It identifies risks to the 

insurance fund by analyzing regional, national, 

and global economic, financial, and financial 

institution developments, and by collecting 

and evaluating information through the 

supervisory process.

Strategic Goal 1

FDIC-insured deposits are protected from loss 

without recourse to taxpayer funding.

Strategic Objectives

1.1 The FDIC provides customers of failed 

insured depository institutions (IDIs) timely 

access to insured funds and financial 

services.

Means and Strategies: When an institution 

fails, the FDIC facilitates the transfer of the 

institution’s insured deposits to an assuming 

institution or pays insured depositors directly. 

The FDIC’s goal is to provide customers with 

access to their insured deposits within one to 

two business days. 

The FDIC continually monitors changes in 

financial institution operations and innovation 

within products and delivery channels to 

ensure the FDIC’s ability to handle potential 

financial institution failures. The FDIC 

develops, tests, and maintains contingency 

plans to ensure it is prepared to handle a wide 

range of potential failure scenarios, including 

the failure of a large financial institution; 

simultaneous, multiple failures; the failure of 

an institution with large international 

holdings; and the failure of an insured 

institution that operates primarily through 

digital channels. The FDIC also looks for ways 

to clarify deposit insurance regulations to 

meet industry changes and to expedite the 

insurance determination process.
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External Factors: The goal of providing 

customers of failed institutions with access to 

their insured deposits within one to two 

business days is well established, but might be 

difficult to achieve in the case of an extremely 

large or complex institution or a sudden and 

unexpected failure. Regardless of timing to 

complete all deposit insurance 

determinations, no depositor would ultimately 

lose any portion of an insured deposit.

1.2 The FDIC promptly identifies and 

responds to potential risks to the Deposit 

Insurance Fund (DIF).

Means and Strategies: The FDIC, in 

cooperation with the other primary federal 

regulators, proactively identifies and evaluates 

the risk and financial condition of individual 

IDIs. It also identifies broader economic and 

financial risk factors, including the evolving 

technological landscape, that affect all insured 

institutions. It accomplishes these objectives 

through a wide variety of activities including 

the following:

• A risk-based deposit insurance assessment 

system, whereby institutions that pose 

greater risk to the DIF pay higher 

premiums;

• A strong examination and enforcement 

program;

• Collection and publication of detailed 

banking data and statistics; 

• A vigorous research program;

• An off-site monitoring system that employs 

sophisticated predictive tools to analyze 

and assess changes in banking profiles, 

activities, and risk factors;

• A comprehensive ongoing analysis of the 

risks in financial institutions with more 

than $10 billion in assets through the Large 

IDI Program and Institution Monitoring 

Program for LCFIs, including IDIs with 

assets above $100 billion for which the 

FDIC is not the primary federal regulator;

• Thorough and timely review of deposit 

insurance applications and other 

applications from IDIs; and

• A comprehensive framework for 

continually assessing risks to the banking 

industry.

External Factors: In spite of the 

comprehensive efforts undertaken by the FDIC 

to identify and respond to potential risks to the 

DIF, natural disasters, public policy changes, 

and sudden economic or financial market 

crises could cause broad losses within the 

financial services industry and the DIF. In 

addition, a fraud perpetrated on a financial 

institution could result in a sudden and 

unforeseen loss to the DIF.

1.3 The FDIC maintains a strong and 

adequately financed DIF.

Means and Strategies: The FDIC maintains 

the viability of the DIF by investing the fund, 

monitoring and responding to changes in the 

reserve ratio, collecting risk-based premiums, 

and evaluating the deposit insurance system in 

light of an evolving financial services industry. 
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It regularly analyzes the growth or shrinkage of 

estimated insured deposits, the current 

assessment base, loss expectations, interest 

income earned on the fund, and operating 

expenses. This information is used to develop 

a schedule of risk-based assessment rates.

The banking industry remained resilient 

through 2021, despite the extraordinary 

challenges of the pandemic. As of September 

30, 2021, banks held a higher amount and 

quality of capital than just prior to the 2008-

2013 banking crisis. 

The DIF balance has risen every quarter since 

the end of 2009, and stood at a record $121.9

billion on September 30, 2021, up from $117.9

billion at the end of 2020. The reserve ratio 

stood at 1.27 percent at September 30, 2021, 

down from 1.29 percent at the end of 2020.

Extraordinary growth in insured deposits 

during the first and second quarters of 2020 

caused the reserve ratio to decline below the 

statutory minimum. As of June 30, 2020, the 

reserve ratio stood at 1.30 percent. On 

September 15, 2020, the Board adopted a 

Restoration Plan, as required by the FDI Act, to 

restore the DIF to at least 1.35 percent within 

eight years. Under the Restoration Plan, the 

FDIC maintained the schedule of assessment 

rates in place at the time for all IDIs and is 

monitoring deposit balance trends, potential 

losses, and other factors that affect the reserve 

ratio. Staff must update the Board at least 

semiannually. The most recent update was 

provided on June 15, 2021. 

The FDIC Board of Directors is statutorily 

required to establish a Designated Reserve 

Ratio (DRR) for the DIF that is not less than 1.35 

percent. But it may also establish a higher DRR 

and has set the DRR at 2.0 percent for every 

year since 2011. The FDIC views the 2.0 

percent DRR as a long-term goal and the 

minimum level needed to withstand future 

crises of the magnitude of past crises.

External Factors: Projections for the DIF are 

subject to considerable uncertainty. The FDIC 

will monitor deposit balance trends, potential 

losses, and other factors that affect the reserve 

ratio. The economic outlook has 

strengthened, and the banking system appears 

better positioned to withstand losses 

compared to prior periods of stress. Several 

factors, such as slower than expected

economic growth, market volatility, or 

additional fiscal and monetary stimulus could 

result in increased insured deposit growth or 

losses to the fund.

1.4 The FDIC resolves failed IDIs in the 

manner least costly to the DIF.

Means and Strategies: When an institution 

fails, the FDIC facilitates an orderly, least-cost 

resolution. Using an estimated value of the 

failing institution’s assets and liabilities, the 

FDIC markets the institution to potential 

bidders. After analyzing the bids received, the 

FDIC conducts a least-cost test determination 

and selects the least-cost strategy to pursue. 
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External Factors: In accordance with law, if a 

failure threatens serious adverse systemic 

effects on economic conditions or financial 

stability, resolution strategies other than the 

least-cost resolution may be employed.

1.5 The FDIC provides the public and IDIs

access to clear and accurate information 

about federal deposit insurance coverage. 

Means and Strategies: To inform consumers 

and FDIC-insured institutions about federal 

deposit insurance coverage, the FDIC provides 

financial institutions with a variety of 

educational tools and materials designed to 

help customers understand their deposit 

insurance coverage.

In addition, the FDIC uses several other 

approaches to disseminate information on 

deposit insurance coverage, including the 

following:

• Operation of a National Center for 

Consumer and Depositor Assistance

staffed by specialists who respond to 

questions from depositors and bankers3

,

• Training and other educational 

opportunities to help bank employees 

better understand the FDIC’s deposit 

insurance rules,

• An array of web-based educational 

resources for consumers and bankers, and

3 877-ASK-FDIC (877-275-3342); 800-925-4618 (TDD-for hearing impaired).

• A wide range of publications and videos 

explaining how FDIC deposit insurance 

works.

External Factors: A significant rise in the 

volume of bank failures, or publicity that raises 

public concerns about the possibility of 

significant bank failures, could result in bank 

runs by misinformed depositors or public 

avoidance of IDIs. Timely, accurate, and 

understandable information is essential to 

mitigating these risks. An increased volume of 

bank failures and public concern about the 

possibility of additional failures could also 

result in substantial increases in the demand 

for information about FDIC insurance coverage 

that could temporarily exceed the FDIC’s 

capacity to provide such information. In such 

cases, the FDIC would augment staff resources 

for this function as quickly as possible.
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Supervision Program

Program Description

The FDIC is the insurer for all IDIs in the United 

States, and the primary federal supervisor for 

state-chartered banks and savings institutions 

that are not members of the Federal Reserve 

System.4

 The FDIC’s roles as an insurer and 

primary supervisor are complementary, and 

many activities undertaken by the FDIC 

support both the insurance and supervision 

programs. Through conducting examinations, 

review of examination reports, use of off-site 

monitoring tools, and participation in 

examinations conducted by other federal 

regulators (either through agreements with 

these regulators or, in limited circumstances, 

under the exercise of the FDIC’s authority to 

conduct special (backup) examination 

activities), the FDIC regularly monitors the 

potential risks at all insured institutions, 

including those for which it is not the primary 

federal supervisor. The FDIC also takes into 

account supervisory considerations in the 

exercise of its authority to review and approve 

applications for deposit insurance from new 

institutions and other applications from IDIs, 

regardless of the chartering authority.

In addition, the FDIC has statutory 

responsibilities for certain bank holding 

companies and nonbank financial companies 

that are designated as systemically important. 

4 This includes state-licensed insured branches of foreign banks. As of 3/31/21, the FDIC had primary supervisory 

responsibility for 3,209 FDIC-insured, state-chartered commercial banks and savings institutions that are not members of the 

Federal Reserve System (generally referred to as “state non-member” institutions). 

The FDIC and FRB have joint responsibility for 

reviewing and assessing resolution plans 

developed by these companies that 

demonstrate how they would be resolved in a 

rapid and orderly manner in the event of 

financial distress. 

The FDIC pursues the following three strategic 

goals in fulfilling its supervisory 

responsibilities as the primary federal 

supervisor for state non-member banks and 

savings institutions, the backup supervisor for 

other FDIC-insured institutions, and the 

reviewer of resolution plans:

• FDIC-insured institutions are safe and 

sound.

• FDIC-supervised institutions are compliant 

with applicable laws, including federal 

consumer protection laws, fair lending 

laws, and the Community Reinvestment 

Act (CRA).

• Large, complex financial institutions are 

resolvable in an orderly manner.

The FDIC promotes safe and sound financial 

institution practices through regular risk 

management examinations; publication of

regulations, guidance and policy; ongoing 

communication with industry officials; and the 

review of applications submitted by FDICsupervised institutions, and in certain cases, 

non FDIC-supervised institutions, to expand 
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their activities or locations. The FDIC also 

evaluates deposit insurance applications for 

de novo institutions, regardless of charter 

type. When appropriate, the FDIC has a range 

of informal and formal options available to 

require management to resolve safety-andsoundness problems identified at troubled

institutions. The FDIC also has staff dedicated 

to administering off-site monitoring programs 

and to enhancing the agency’s ability to timely 

identify emerging safety-and-soundness 

issues.

The FDIC promotes compliance by FDICsupervised institutions with federal consumer 

protection laws, fair lending statutes, and 

community reinvestment laws through a 

variety of activities, including ongoing 

communication with industry officials, regular 

compliance and Community Reinvestment Act 

(CRA) examinations, dissemination of 

information to consumers about their rights 

and required disclosures, and investigation 

and resolution of consumer complaints 

regarding FDIC-supervised institutions. The 

FDIC also has a range of informal and formal 

enforcement options available to resolve 

compliance problems identified at these 

institutions and their institution-affiliated 

parties.

The FDIC’s assessment of the resolution plans 

submitted by bank holding companies, other 

covered companies, and IDIs helps develop 

and improve its capabilities to administer large 

resolutions under any of the available 

authorities. For example, the actions firms 

take to address the shortcomings identified by 

the FDIC and the Federal Reserve Board in 

their resolution plans are intended to address 

potential impediments to resolvability under 

the Bankruptcy Code. That work in turn 

informs the FDIC’s strategic planning to 

conduct an orderly liquidation under the FDI 

Act or the Orderly Liquidation Authority (OLA), 

if necessary, to protect U.S. financial stability.

The FDIC may be called upon to resolve the 

failure of a large, systemically important 

financial company if failure under the 

Bankruptcy Code would threaten U.S. financial 

stability. In such circumstances, the authority 

exists to place the failed or failing financial 

company into an FDIC receivership process if 

no viable private-sector alternative is available 

to prevent the default of the company. The 

OLA is intended to ensure the rapid and 

orderly resolution of the failure of such a 

financial company in accordance with 

statutory mandates. The FDIC actively 

engages in, and will continue to refine, 

resolution plans and strategies and 

operational readiness initiatives to ensure that 

it is prepared, if necessary, to fulfill this 

responsibility.
17 | Page

Supervision Program – Risk 

Management

Strategic Goal 2

FDIC-insured institutions are safe and sound.

Strategic Objective

2.1 The FDIC exercises its statutory 

authority, in cooperation with other 

primary federal regulators and state 

agencies, to promote safe and sound 

practices at FDIC-insured institutions, 

including appropriate risk management.

Means and Strategies: As noted above, the 

FDIC is the primary federal supervisor for all 

state non-member banks and state-chartered 

savings institutions. For those institutions, the 

FDIC performs risk management (safety and 

soundness), trust, Bank Secrecy Act/AntiMoney Laundering, and Information 

Technology (IT) examinations in cooperation 

with state banking regulators. Most state 

banking agencies participate in an 

examination program under which certain 

community bank examinations are performed 

on an alternating basis by the state agency and 

the FDIC. The FDIC supervises regional banks 

jointly with the applicable states under a 

continuous examination model. 

In addition, the FDIC, OCC, and FRB conduct IT 

examinations of third-party technology service 

providers that provide a range of services to 

IDIs. As the threat of cyberattacks continues to 

be prominent, the FDIC engages with other 

regulators and the private sector to encourage 

IDIs and service providers to implement strong 

preventive programs and to exercise and refine 

protocols for addressing cyber events when 

preventive programs are overcome.

Risk management examinations are conducted 

according to statutorily established 

timeframes. Regional bank examinations are 

conducted on a continuous basis throughout 

the calendar year. Both community bank and 

regional bank examinations assess an 

institution’s overall financial condition, 

management practices and policies, 

compliance with applicable laws and 

regulations, and the adequacy of management 

and internal control systems to identify, 

measure, and control risks. Examination 

procedures may also detect the presence of 

fraud or insider abuse. In addition, the FDIC 

reviews the risk management capabilities of 

those FDIC-supervised institutions that apply 

for permission to engage in new or expanded 

business activities, including those associated 

with innovative technologies.

Communication and corrective action are 

important components of the FDIC’s strategy 

for promoting the safety and soundness of the 

institutions it supervises. Risks identified 

during an examination are discussed with the 

institution’s management and board of 

directors. If an examination reveals serious 

weaknesses in the operations of the institution 

or indicates that the institution is operating in 

a weakened financial condition, the FDIC may 

issue formal or informal enforcement actions 

that remain in effect until corrective actions 

are taken and the identified weaknesses are 

addressed. 
18 | Page

In the case of severe problems, the institution 

may be instructed to seek additional capital, 

merge with another institution, or liquidate.

The FDIC monitors individual institutions it 

supervises between examinations, and 

emerging trends across institutions, by 

analyzing Call Report data and examination 

findings relative to the emerging trends. To 

perform this analysis, the FDIC uses a 

combination of traditional analytical tools, and 

machine learning techniques. The FDIC’s 

statutory authority also gives it a degree of 

supervisory responsibility in its role as insurer 

for IDIs for which it is not the primary federal 

supervisor. The agency has staff in each of its 

regional offices that regularly review 

examination reports and other available 

information from the primary federal 

regulators for those institutions.

The FDIC also performs off-site monitoring of 

those institutions on an ongoing basis. In 

addition, certain larger, more complex

institutions are subject to more frequent 

onsite reviews and more robust off-site and 

ongoing monitoring. The FDIC also has the 

authority to conduct special (backup) 

examination activities for institutions for 

which is not the primary federal regulator. 

Under this authority, the FDIC participates in 

examinations of certain IDIs that present 

heightened risk to the DIF and designated 

large, complex IDIs.

Ensuring the safety and soundness of FDICinsured institutions over the next four years 

will require an effective supervisory program 

that incorporates the lessons learned from 

past financial crises and the recent health 

pandemic, identifies potential new risks that 

emerge, and responds quickly to such issues in 

an effective manner that maximizes the use of 

technology. The economic impact of the 

pandemic and potential longer-term shifts in 

demand for various property types, products 

and services create significant uncertainty for 

the coming period. Government stimulus 

programs have helped prevent asset quality 

deterioration, thus far, and have led to 

significant deposit inflows at institutions of all 

sizes. The low interest rate environment has 

negatively impacted institutions’ earnings, 

with net interest margins falling to historic 

lows. These factors combine to create a 

challenging operating environment for 

institutions. The pandemic-related shift to 

working from home also led to an increase in 

cybersecurity threats and attacks across all 

industries. Innovation creates opportunities 

for managing through these changes, 

including in creating more resilient 

information technology infrastructures. 

Through regular on-site examinations and 

interim contacts with state non-member 

institutions, FDIC staff will actively engage in a 

constructive dialogue with banks to ensure

that their policies to manage financial and 

operational risks are effective, and, where 

appropriate, FDIC staff will work closely with 

institutions that have significant exposure to 

these risks and encourage them to take 

appropriate steps to mitigate risks. 
19 | Page

The FDIC will use off-site monitoring to help 

identify institutions with outsized risk 

exposures and follow up with individual 

institutions to better understand their risk 

profiles.

Additionally, the FDIC will continue its efforts 

to promote offsite examination work where 

possible, by leveraging technologies used and 

lessons learned while examining through the 

pandemic. Cybersecurity is a risk area that will 

continue to receive particular attention. 

During this period, the FDIC will refine its IT 

examination program for insured institutions 

and major technology service providers, and 

increase its already robust collaboration with 

other regulators, law enforcement, and 

security agencies. In addition, in light of the 

risks posed to the DIF by large and complex 

banks and the FDIC’s responsibilities for 

systemically important financial institutions 

(SIFIs), the agency will continue to enhance its 

supervisory monitoring program for large and 

complex banks.

The FDIC dedicates significant resources to the 

continuing identification of emerging issues. It 

regularly reviews supervisory information from 

the thousands of examinations that are 

conducted annually as well as information 

from a variety of external data sources to 

identify and, where appropriate, initiate 

supervisory responses to newly identified 

areas of risk. For example, the FDIC is 

currently monitoring trends, opportunities, 

and risks in innovative technologies; 

evaluating the impact of innovation on 

banking, deposit insurance, oversight, 

inclusion, and consumer protection; and 

formulating strategy to respond to 

opportunities and challenges presented by 

technological innovation to supervised 

institutions. 

The FDIC also dedicates significant resources 

to developing and implementing supervisory 

technology (SupTech). Examples of SupTech 

that will be expanded over the coming years 

are a machine learning tool that identifies 

trends across examinations and pertinent 

weaknesses at individual institutions, an offsite monitoring tool that analyzes Call Report 

data to identify institutions vulnerable to 

financial deterioration, and analytical tools 

derived from a rapid prototyping competition 

that will allow analysis of more granular bank 

data on a more regular basis between 

examinations, supporting earlier identification 

of any problems at the institutions, across the 

financial sector, or in particular economic 

areas. 

The FDIC promotes safety and soundness 

through the development of or modification to 

regulatory policy. Identification of new or 

emerging risks may lead to a variety of policy 

responses depending on the nature and 

severity of the risk. The FDIC devotes 

significant resources to both domestic and 

international policy development and works 

collaboratively with other regulatory bodies in 

an effort to bolster the financial resilience of 

the banking system. 
20 | Page

While banks generally performed well through 

the global health crisis, the period of 

disruption offers an opportunity to evaluate 

policy effectiveness while also addressing any 

identified weaknesses.

The FDIC actively works to fulfill five statutory 

goals to support the preservation of minority 

depository institutions (MDIs). In addition to its 

outreach, technical assistance, and training 

and education programs, the FDIC facilitates 

engagement with MDIs and other missiondriven institutions; highlights the role they 

play in community development; promotes 

public and private partnerships to provide 

tools and resources to support these 

institutions; and explores ways to remove 

barriers to adoption of innovative technologies 

by these banks.

The FDIC has established and consults 

regularly with the Advisory Committee on 

Community Banking (CBAC), which advises the 

FDIC on the impact of FDIC supervisory policies 

and practices on community banks. Members 

of the Advisory Committee have a wide range 

of knowledge and experience related to 

community banks. The FDIC also engages 

regularly with the MDI Subcommittee of the 

CBAC.

External Factors: Several factors outside of 

the FDIC’s control could affect the successful 

achievement of this strategic objective. In 

accordance with statutorily established time 

frames, most risk management examinations 

of well-capitalized and well-managed state 

non-member institutions are point-in-time 

examinations that occur at 18-month intervals. 

Between examinations, institutions may enter 

new lines of business, extend their lending 

programs into riskier areas, or implement new 

technologies without the knowledge of the 

FDIC or state regulatory agencies. Major 

changes in economic conditions could also 

affect institutions between examinations. The 

FDIC will continue to improve off-site tools to 

analyze potential risks that may develop 

between examinations at individual 

institutions or across the financial sector.
21 | Page

Supervision Program –

Consumer Protection and 

Economic Inclusion

Strategic Goal 3

FDIC-supervised institutions are compliant 

with federal consumer protection laws, 

including fair lending laws, and the 

Community Reinvestment Act (CRA).

Strategic Objectives

3.1 The FDIC supervises institutions for 

compliance with applicable federal 

consumer protection laws, including fair 

lending laws; the law against unfair and

deceptive practices; and the CRA.

3.2 The FDIC provides clear and accessible

information to consumers about their rights 

under federal consumer protection and fair 

lending laws and regulations, including 

applicable disclosures.

3.3 The FDIC encourages IDIs to offer 

affordable checking and savings accounts 

and loan products that meet the needs of 

consumers.

The means and strategies used to achieve 

these strategic objectives and the external 

factors that could impact their achievement 

are described below.

3.1 The FDIC supervises institutions for 

compliance with applicable federal 

consumer protection laws, including fair 

lending laws; the law against unfair and

deceptive practices; and the CRA.

Means and Strategies: The FDIC pursues this 

strategic objective primarily through 

compliance and CRA examinations of all FDICsupervised institutions. CRA examinations are 

subject to statutory timelines, while 

compliance examinations are conducted 

according to timeframes established by FDIC 

policy. These examinations evaluate 

institutions’ compliance with consumer 

protection laws, unfair and deceptive acts or 

practices, CRA, and fair lending laws and 

regulations. 

If an examination reveals violations, the FDIC 

may implement either formal or informal 

enforcement actions to correct the identified 

violations. In unusual cases, non-compliance 

with consumer laws may subject the 

institution to significant legal risk, and could 

result in administrative enforcement actions or 

private litigation. In addition, when the FDIC 

has reason to believe that a “pattern or 

practice” of violations of fair lending laws has 

occurred at an institution, the FDIC is required 

by statute to refer the matter to the 

Department of Justice. An institution’s failure 

to comply with consumer protection, CRA, or 

fair lending laws and regulations might also 

affect the application of an FDIC-supervised 

institution seeking to engage in new or 

expanded business activities.

The FDIC sponsors or participates in numerous 

outreach and technical assistance activities 

designed to facilitate better understanding of 

and compliance with CRA, consumer 

protection, and fair lending laws and 

regulations by FDIC-supervised institutions. 
22 | Page

In addition, it actively participates in 

interagency policy development efforts and 

issues policy guidance. The FDIC focuses its 

examinations and other supervisory activities 

on those industry products, services, and 

practices that have the highest potential risk 

for violations of law that may result in 

potential harm to consumers.

External Factors: Most compliance and CRA 

examinations are point-in-time examinations 

that occur at scheduled intervals in 

accordance with FDIC policy. Between 

examinations, institutions may implement new 

products, services, or practices that hold 

significant potential risk for consumer harm 

without the knowledge of the FDIC. In 

addition, major changes in economic 

conditions could also affect institutions 

between examinations. During economic 

downturns, institutions sometimes elect to 

reduce costs by decreasing their internal 

resources dedicated to compliance.

3.2 The FDIC provides clear and accessible

information to consumers about their rights 

under applicable federal consumer 

protection and fair lending laws and 

regulations, including applicable 

disclosures.

Means and Strategies: The FDIC provides 

information about consumer protection and 

fair lending laws and regulations to help 

consumers understand their rights. This 

information is disseminated through 

brochures and other venues including social 

media, and the FDIC’s website 

(https://www.fdic.gov). The FDIC Consumer 

News is a monthly online newsletter for 

consumers, providing practical guidance on 

becoming a smarter, safer user of financial 

services. In addition, the FDIC frequently 

conducts or participates in educational 

seminars and conferences on consumer 

protection and fair lending issues to help both 

consumers and insured institutions better 

understand consumer protection, CRA, and fair

lending laws and regulations.

The FDIC maintains a National Center for 

Consumer and Depositor Assistance for 

investigating and responding to consumer 

complaints about FDIC-supervised institutions 

and deposit insurance inquiries under

established target timeframes. FDIC also 

promotes greater financial education and wellbeing, primarily through its award-winning 

Money Smart curriculum. The FDIC will 

continue to keep the Money Smart content 

relevant and research-based, while expanding 

collaborative relationships that result in its 

use. 

External Factors: Although the FDIC makes 

information available to a broad array of 

consumers, individual consumers may not 

always use it. In addition, increasing 

complexity and aggressive and targeted 

marketing increase the challenges consumers 

face in evaluating alternatives in the 

marketplace.
23 | Page

3.3 The FDIC encourages IDIs to offer 

affordable checking and savings accounts 

and loan products that meet the needs of 

consumers.

Means and Strategies: The FDIC has played a 

leadership role in recent years in promoting 

broader economic inclusion of underserved 

households within the nation’s banking system 

through the availability of safe and affordable 

transaction and saving accounts, as well as the 

opportunity to build credit profiles and borrow 

money to meet their needs. Most recently, 

FDIC Launched #GetBanked, a public 

awareness campaign encouraging consumers 

to open an account, harnessing the 

opportunity for millions of unbanked 

Americans to receive COVID-19 relief 

government payments safely and securely. 

Also, the FDIC’s Money Smart financial 

education curriculum is a key tool for pursuing 

this objective by helping target populations 

gain practical knowledge, skills-building 

opportunities, and resources they can use to 

manage their finances with confidence. The 

FDIC also sponsors or conducts research and 

demonstration projects, develops policy 

proposals, facilitates partnerships, and 

participates in targeted outreach and technical 

assistance activities with both the institutions 

it supervises and various community-based 

organizations to further this objective. 

The FDIC established and supports the 

Advisory Committee on Economic Inclusion to 

inform and support its economic inclusion 

strategies and to promote sound supervisory 

and public policies to help ensure that 

underserved households have access to 

mainstream financial products and services 

that are affordable, easy to understand, and 

not subject to unfair or unforeseen fees. In 

addition, on a biennial basis, the FDIC 

conducts jointly with the U.S. Census Bureau 

the only comprehensive, nationwide research 

survey called “How America Banks” regarding

the number of banked and unbanked

households in the U.S. The FDIC also engages 

banks; other federal, state and local 

government agencies; and non-profit 

organizations serving a broad spectrum of 

consumers and small businesses in building 

locally based coalitions to participate in 

financial education and information sharing. 

These coalitions promote local economic 

inclusion opportunities in communities where 

financial health and well-being has lagged the 

rest of the country. In each state and territory 

in the US, at least one FDIC Community Affairs 

specialist has responsibilities to promote 

economic inclusion. Some markets also have 

an Alliance for Economic Inclusion.

The FDIC will continue to pursue multi-year 

initiatives to support broader economic 

inclusion such as promoting account opening, 

strategies to improve financial well-being, 

build savings and improve credit records, and 

evaluate new technologies that can be 

responsibly used to expand banking services 

to underserved populations. The FDIC also will 

continue to work with federal and local 

partners to facilitate community development 

through affordable housing, small business 

development, and related initiatives.
24 | Page

External Factors: The access to credit of 

underserved households from mainstream 

financial institutions could be 

disproportionately affected during economic 

downturns or periods of economic stress. 

Changing technological and market conditions 

could also positively or negatively affect 

opportunities to expand economic inclusion in 

the nation’s banking system.

Supervision Program –

Resolution Planning

Strategic Goal 4

Large, complex financial institutions are 

resolvable in an orderly manner. 

Strategic Objective

4.1 Large, complex financial institutions are 

resolvable under the bankruptcy code or, 

for covered IDIs, the Federal Deposit 

Insurance (FDI) Act, as applicable.

4.2 In the event of the failure of a large, 

complex financial institution, the FDIC 

carries out the resolution in an orderly 

manner in accordance with statutory 

mandates.

The means and strategies used to achieve 

these strategic objectives and the external 

factors that could impact their achievement 

are described below.

4.1 Large, complex financial institutions are 

resolvable under the bankruptcy code or, 

for covered IDIs, the Federal Deposit 

Insurance (FDI) Act, as applicable.

Means and Strategies: Certain large financial 

companies are required to prepare and submit 

annually to the FDIC and FRB resolution plans, 

or “living wills,” demonstrating that they could 

be resolved in a rapid and orderly manner 

under the Bankruptcy Code (or other 

applicable insolvency regime) in the event of 

material financial distress or failure. Among 

other things, the resolution plans must identify 

each firm’s critical operations, core business 

lines, and the key obstacles to a rapid and 

orderly resolution. The FDIC and FRB share 

responsibility for reviewing the plans, 

assessing informational completeness and 

resolvability under the Bankruptcy Code, 

identifying and requiring firms to address any 

shortcomings, and providing firms with 

guidance on the submission of future plans. 

The FDIC has a complementary rule that 

requires certain IDIs to periodically submit 

resolution plans that would enable the FDIC, 

as receiver, to resolve their failure in an 

orderly, least-costly manner.

The FDIC’s review of resolution plans is 

intended to improve the resolvability of bank 

holding companies (and other designated 

financial companies) through the bankruptcy 

process and their subsidiary IDIs through the 

FDIC’s traditional resolution processes as 

deposit insurer. These reviews enhance the 

FDIC’s ability to prepare for possible large 

resolutions and its understanding of how the 

FDIC’s resolution authorities could be best 

used. The FDIC has established on- and off-site 

monitoring and risk assessment programs that 

support the FDIC’s review of the resolution 

plans submitted by these companies.
25 | Page

In addition, the FDIC employs multidisciplinary 

teams that include both supervisory and 

receivership management expertise in the 

review of these plans. The FDIC also 

collaborates closely with the primary federal 

supervisors for the affected IDIs in the review 

of these plans.

External Factors: The rapid and orderly 

resolution of a large, complex financial 

institution under either bankruptcy or Orderly 

Liquidation Authority may be complicated by 

legal and operational concerns that stem from 

the cross-border operations of many large, 

complex financial institutions. The FDIC 

actively works with foreign authorities to 

address these issues.

In addition, the sheer size and complexity of 

these firms pose legal and operational 

challenges to their resolution. Preplanning 

and structural and operational reforms by 

these companies are essential to achieving a 

rapid and orderly resolution under any legal 

framework. 

4.2 In the event of the failure of a large, 

complex financial institution, the FDIC 

carries out the resolution in an orderly 

manner in accordance with statutory 

mandates.

Means and Strategies: Large, complex 

financial institutions in the United States 

historically have been organized under a 

holding company structure, with a top-tier 

parent and operating subsidiaries that 

comprise hundreds, or even thousands, of 

interconnected entities that share funding and 

support services and span legal and regulatory 

jurisdictions across international borders. 

Functions and core business lines often are not 

aligned with individual legal entity structures, 

and critical operations cross legal entities and 

jurisdictions, with funding dispersed among 

affiliates as needs arise. These integrated legal 

structures present obstacles to the orderly 

resolution of one part of the company without 

triggering a costly collapse of the entire 

company and potentially transmitting adverse 

effects throughout the financial system.

To improve the ability of firms to be resolved in 

bankruptcy, the FDIC and FRB have worked 

closely with firms, and provided detailed 

feedback regarding key issues and obstacles to 

orderly resolution in bankruptcy. In response, 

firms have made significant changes to their 

operations and legal structure. The agencies 

also have fostered significant public 

transparency surrounding the resolution 

planning process to improve the public’s 

understanding of the progress that has been 

made. In addition to taking steps to improve 

resolvability under bankruptcy (the statutorily 

preferred option), the FDIC has been preparing 

contingency plans for firms to be resolved 

under the OLA, should that be necessary to 

protect U.S. financial stability. 

To ensure the FDIC’s operational readiness to 

conduct the resolution of a large, complex 

financial institution, the FDIC continues to 

update and refine its firm-specific contingency 

plans. In addition, the FDIC is developing 

operational procedures for administration of a 

receivership, if necessary. 
26 | Page

The FDIC conducts simulations and tabletop 

exercises and undertakes joint contingency 

planning with other U.S. and foreign regulatory 

authorities to enhance communications and

operational readiness, and it is exploring other 

opportunities to collaborate with U.S. and 

foreign authorities to ensure effective 

coordination and cooperation in a resolution.

In addition, the FDIC, together with other U.S. 

financial regulatory agencies, continues to 

develop its relationships with key regulatory 

authorities in other countries to facilitate 

closer coordination and cooperation in the 

event of the failure of a global SIFI. The FDIC 

also analyzes emerging issues and is 

enhancing its understanding of the legal and 

policy structures in other countries that might 

affect a rapid and orderly resolution.

The FDIC established the Systemic Resolution 

Advisory Committee to advise on the potential 

effects the failure of a large, complex financial 

institution would have on financial stability 

and economic conditions. Members of the 

Advisory Committee bring a wide range of 

knowledge and experience to resolutionrelated issues, including expertise in managing 

complex firms, administering bankruptcies, 

working within different legal jurisdictions, 

and understanding the application of 

accounting rules and practices.

External Factors: The specific facts 

surrounding the failure of a large, complex 

financial institution may affect the FDIC’s 

ability to execute a resolution as planned, 

especially considering the complex and 

interconnected nature and global reach of 

these firms. As part of its contingency 

planning efforts, the FDIC will seek to mitigate 

this risk by collecting and maintaining 

comprehensive, up-to-date information on 

these institutions that will support a rapid and 

orderly resolution, if that becomes necessary.
27 | Page

Receivership Management 

Program

Program Description

When an IDI fails, the FDIC is ordinarily 

appointed receiver. In that capacity, it 

assumes responsibility for efficiently 

recovering the maximum amount possible 

from the disposition of assets and the pursuit 

of claims in the receivership. Funds that are 

collected from the sale of assets and the 

disposition of valid claims are distributed to 

the creditors of the receivership according to 

priorities set by law.

The FDIC seeks to terminate receiverships in 

an orderly and expeditious manner. Once the 

FDIC has completed the disposition of the 

receivership’s assets and has resolved all 

obligations, claims, and other legal 

impediments, the receivership is terminated, 

and a final distribution is made to its creditors. 

Receivership creditors may include secured 

creditors, unsecured creditors (including 

general trade creditors), subordinate debt 

holders, shareholders, uninsured depositors, 

and the DIF (as subrogee). The FDIC, in its 

corporate capacity, is often the largest creditor 

of the receivership.

Strategic Goal 5

Resolutions are orderly and receiverships are 

managed effectively.

Strategic Objectives

5.1 The FDIC manages receiverships to 

maximize net return and terminates them in 

an orderly and timely manner.

5.2 The FDIC investigates potential

recoveries, including claims against 

professionals, and pursues them if deemed 

to be meritorious and expected to be costeffective.

The means and strategies used to achieve 

these strategic objectives and the external 

factors that could impact their achievement 

are described below.

5.1 The FDIC manages receiverships to 

maximize net return and terminates them in 

an orderly and timely manner.

Means and Strategies: Under the FDIC Act, 

the FDIC, in its receivership capacity, manages 

the assets of failed IDI receiverships to 

preserve their value and to dispose of them as 

quickly as possible, consistent with the 

objective of maximizing the net return on 

those assets. The oversight and prompt 

termination of receiverships preserves value 

for the uninsured depositors and other 

receivership claimants by reducing overhead 

and other holding costs. By quickly returning 

the assets of a failed institution to the private 

sector, the FDIC maximizes net recoveries and 

minimizes disruption to the local community. 
28 | Page

In fulfilling its responsibilities to creditors of 

failed institutions, the FDIC, as receiver, 

manages and sells the receivership assets 

using a variety of strategies. Given adequate 

time to prepare for a resolution, the FDIC 

develops a virtual data room and an asset 

valuation review to solicit bidders and sell as 

many of the IDI’s assets as possible at closing

or shortly thereafter. The FDIC manages the 

remaining assets in a cost-effective manner to 

preserve value until they can be marketed and 

sold. Most of the remaining assets are 

marketed within 120 days after an IDI fails

unless they are identified for an alternative 

disposition strategy (i.e., joint venture or 

securitization). 

External Factors: A severe economic 

downturn could lead to more IDI failures and 

could affect the pace at which the FDIC 

markets assets and terminates receiverships. 

Other factors, such as extended litigation and 

problems resolving environmentally tainted 

receivership properties, might also delay the 

termination of a receivership.

5.2 The FDIC investigates potential

recoveries, including claims against 

professionals, and pursues them if deemed 

to be meritorious and expected to be costeffective.

Means and Strategies: When an IDI fails, the 

FDIC, as receiver, acquires a group of legal 

rights, titles, and privileges generally known as 

professional liability claims. The FDIC’s 

attorneys and investigators work together to 

identify and pursue claims arising from the 

failure of an IDI that are deemed to be 

meritorious and expected to be cost-effective. 

The team conducts a factual investigation of 

the events that contributed to losses at the IDI

as well as legal research and analysis of the 

facts and potential claims. Innovative data 

capture and analytics techniques are used to 

gain efficiencies throughout the investigative 

process. For each potential claim, the team 

recommends whether the claim should be 

pursued based on an assessment of its merits 

and the likelihood of a recovery exceeding the 

estimated cost of pursuing the claim. The 

timely investigation and evaluation of 

potential claims enables the FDIC to identify 

opportunities to maximize recoveries to each 

receivership and to hold accountable 

directors, officers, and professionals who 

cause losses to IDIs. This process also 

enhances industry awareness of sound 

corporate governance standards. 

External Factors: Potential claims are 

generally subject to statutes of limitations that 

establish time limits for the claim to be filed. A 

substantial increase in the number of failures 

could make it difficult to complete 

investigations of all potential claims and 

determine within the established time limit 

whether to pursue claims. The same situation

could occur with very complex investigations 

or claims. Other obstacles to timely 

investigation and evaluation of claims include 

difficulty accessing critical information or 

witnesses. In such cases, the FDIC may seek to 

enter into tolling agreements with the 

potential defendants to extend the allowable 

timeframe for the claims to be filed.
29 | Page

OFFICE OF INSPECTOR GENERAL

The Office of Inspector General

The FDIC’s Office of Inspector General (OIG) is 

an independent organizational unit 

established under the Inspector General Act of 

1978, as amended, that conducts audits, 

evaluations, investigations, and other reviews 

of FDIC programs and operations. The OIG’s 

mission is to promote the economy, efficiency, 

and effectiveness of FDIC programs and 

operations, and to prevent, deter, and detect 

waste, fraud, abuse, and misconduct in FDIC 

programs and operations.

The OIG aims to drive change and make a 

difference by prompting and encouraging 

improvements and efficiencies at the FDIC, 

help preserve the integrity of the agency and 

the banking system, and protect depositors 

and financial consumers. To accomplish its 

mission and achieve its vision, the OIG has 

established the following six goals:

• Conduct superior, high-quality audits, 

evaluations, and reviews;

• Investigate significant matters of 

wrongdoing and misconduct relating 

to FDIC employees, contractors, and 

institutions;

• Strengthen relations with partners and 

stakeholders;

• Administer resources prudently, safely, 

securely, and efficiently;

• Exercise leadership skills at all levels 

within the organization; and

• Promote teamwork within the Office.

The OIG also has developed internal objectives 

to accomplish these goals.

Additional information about the OIG, 

including a copy of the OIG’s Strategic Plan, 

can be found at https://www.fdicoig.gov.
30 | Page

APPENDICES

Appendix A: The FDIC’s 

Strategic Planning Process

Introduction

The FDIC is subject to the requirements of the 

Government Performance and Results Act 

(GPRA) as modified by the GPRA Modernization 

Act of 2010 and certain provisions of Title I, 

Federal Evidence-Building Activities of the 

Foundations for Evidence-Based Policymaking 

Act of 2018. In accordance with the 

requirements of these statutes, the FDIC 

reviews and updates its Strategic Plan every 

four years, publishes Annual Performance 

Plans and Performance Reports, and conducts 

program evaluations to assess whether the 

agency’s programs are achieving their stated 

purposes.

Annual Performance Plan and Report

The FDIC Strategic Plan is implemented 

through annual performance plans. The 

annual plans identify annual performance 

goals, indicators, and targets for each strategic 

objective. The FDIC submits an Annual Report 

to Congress in February of each year that 

compares actual performance to the annual 

performance goals for the prior year. This 

report is also made available to FDIC 

stakeholders and the public through 

https://www.fdic.gov. 

Long-term strategic goals and objectives are 

expressed in outcome terms, and selected 

outcome measures are included in the 

agency’s annual performance plans. However, 

many of the performance indicators in these 

annual plans are process measures (for 

example, completing required examinations). 

It is often difficult to establish a direct causal 

relationship between the agency’s activities 

and the outcomes experienced by insured 

institutions. The FDIC continues to work with 

the other regulatory agencies to improve its 

performance measures.

Corporate Planning and Performance 

Management Process

The FDIC establishes performance goals 

annually through an integrated planning and 

budgeting process. In formulating these 

performance goals, the agency considers the 

external economic environment, the condition 

of the banking and financial services industry 

(including potential risks), projected workload 

requirements, and other corporate priorities. 

Agency plans also may be influenced by the 

results of program evaluations and 

management studies, prior year performance 

results, and other factors. Based on this 

information, planning guidance is established 

by senior management with input from 

program personnel.

After annual performance goals are 

established, a proposed annual corporate 

operating budget is developed, taking into 

account the financial, human capital, 

technological, and other resources required to 

accomplish core mission responsibilities and 

other annual performance goals. 
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The budget is typically approved by the Board 

of Directors in December.

Annual performance goals are communicated 

to employees through established supervisory 

channels, the internal FDIC website, and other 

means. Staff prepares progress reports, and 

senior management conducts performance 

reviews quarterly.

Stakeholder Consultation

The FDIC requested comment from 

stakeholders and the public on a draft of this 

strategic plan through a posting on the FDIC 

website for a 14-day period in August 2021. All 

comments and suggestions were carefully 

reviewed and changes made to the plan where

appropriate.
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Appendix B: Enterprise Risk 

Management

Enterprise Risk Management

Enterprise Risk Management (ERM) is a way to 

better anticipate, prioritize, and manage risks 

across an agency. The FDIC’s ERM program 

aims to address the full spectrum of significant 

internal and external risks facing the agency 

and the combined impact of those risks as an 

interrelated portfolio.

The FDIC integrates ERM into its strategic 

planning and budgeting processes to inform 

decision-making and resource 

deployment. Each year, the FDIC develops 

funding requests and corporate-wide goals 

that consider identified risks. Higher rated 

risks may warrant increases to financial or 

personnel resources.

Key ERM program components include the 

Risk Appetite Statement, Risk Profile, and Risk 

Inventory. The Risk Appetite Statement serves 

as a guide for setting strategic goals and 

objectives and communicates the 

Corporation’s views about the level of risk 

taking that is acceptable across various agency 

programs and operations. The Risk Appetite 

Statement considers the following eight risk 

categories: strategic, compliance, reporting, 

operational, reputational, financial, 

technological, and external risks. 

FDIC’s Risk Inventory is a comprehensive, 

detailed list of risks that could hamper the 

FDIC’s ability to achieve its goals and 

objectives. Divisions and offices identify risks 

through risk assessments, internal reviews,

audits and evaluations, risk committees, and 

ORMIC research and reviews. Divisions and 

offices assign residual risk level ratings based 

on the impact and likelihood of the risk 

occurring, identify risk mitigations for higherrated risks, and track mitigation activities to 

completion.

The Risk Profile is a prioritized inventory of the 

most significant risks identified and assessed 

through the risk assessment process. ORMIC 

maps underlying Risk Inventory items to 

higher-level Risk Profile items then assigns a 

mitigation coverage level, risk trend, and 

residual risk level to each Risk Profile 

item. ORMIC vets this information with the 

divisions and offices and deputies to the 

Chairman. The Risk Inventory and Risk Profile 

are living documents that are updated as 

needed and formally validated each 

summer. The CRO presents the Risk Profile to 

the FDIC Operating Committee—the FDIC’s 

ERM oversight body—for review, discussion, 

and annual confirmation. The CRO also 

provides quarterly ERM briefings to the 

Chairman and Operating Committee and 

semiannual briefings to the FDIC Audit 

Committee, a standing committee of the FDIC 

Board of Directors.
33 | Page

Appendix C: The FDIC’s Use of 

Research, Data, and Analysis 

to Support Evidence-Based 

Policy Making and Program 

Management

The Foundations for Evidence-Based 

Policymaking Act of 2018 requires the FDIC to 

assess as part of its strategic plan the 

coverage, quality, methods, effectiveness, and 

independence of the statistics, evaluation, 

research, and analysis efforts of the FDIC. The 

FDIC has long recognized that data is one of its 

most important resources for accomplishing 

its mission responsibilities, both for internal 

use and for dissemination to the financial 

industry and other stakeholders. The FDIC 

collects and utilizes data from individual 

financial institutions and other sources to 

assess risks and establish risk-based insurance 

premiums for insured depository institutions 

(IDIs), conduct bank examination and other 

supervisory activities for FDIC-supervised IDIs, 

evaluate the resolution plans of large and 

systemically important IDIs, and resolve IDI 

failures at the least cost to the Deposit 

Insurance Fund. It is essential that this 

information on which the FDIC relies in 

performing these functions be complete and 

accurate. 

Statistics, Data Collection, and Analysis

The FDIC relies on the collection and analysis 

of data from FDIC-insured institutions and 

other sources to carry out virtually all of its 

core business processes. These data are 

aggregated and maintained in multiple 

systems and databases used by employees 

throughout the agency to perform their day-today duties and responsibilities. The major 

systems/databases include the following:

• Central Data Repository (CDR), which 

maintains core financial information 

collected quarterly from all FDICinsured institutions for use by all 

federal bank regulatory agencies.

• Institution Directory (ID), which 

contains comprehensive, up-to-date 

financial and demographic data for 

every FDIC-insured institution. 

• Structure Information Management 

System (SIMS), which holds detailed 

location and demographic information 

on offices and branches of FDICinsured institutions.

• Statistics on Depository Institutions 

(SDI), which maintains the latest 

comprehensive financial and 

demographic data for every FDICinsured institution.

• Summary of Deposits (SOD), which 

collects and maintains annually 

information on branch office deposits 

for all FDIC-insured institutions, 

including insured U.S. branches of 

foreign banks.

• Survey of Household Use of Banking 

and Financial Services, which collects 

information biennially from U.S. 

households (in partnership with the 

U.S. Bureau of the Census) on bank 

account ownership, the primary 
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methods banked households use to 

access their bank accounts, bank 

branch visits, use of prepaid cards and 

nonbank financial transaction services, 

and use of bank and nonbank credit.

• Small Business Lending Survey, a 

nationally representative survey of U.S. 

banks and their small business lending 

practices.

• Failed Bank Data, a unique research 

database that contains detailed 

financial and other information 

collected by the FDIC during the 

resolution of FDIC-insured institution 

failures.

• Enterprise Data Warehouse, which 

provides FDIC employees a centrally 

managed, high-quality, and highly 

secure data platform for corporate and 

divisional data analysis, reporting, and 

decision-making.

The FDIC makes its data and risk analysis 

available to the public through a variety of 

regular publications, including the Quarterly 

Bank Profile, FDIC Quarterly, Supervisory 

Insights Journal, Consumer Compliance 

Supervisory Highlights, and How America 

Banks. It also makes this data available to the 

public for research and other purposes on its 

website through Bank Find Suite, a database 

that identifies whether an institution is FDICinsured and provides detailed historical 

information on the institution, including past 

mergers and acquisitions. The FDIC is 

modernizing its public-facing data and 

analytical tools to improve functionality and 

ease of user access.

Research and Evaluation Activities

As a preeminent banking research 

organization, the FDIC maintains a vigorous 

research and publications program, managed 

by its Division of Insurance and Research (DIR), 

on an array of issues and topics of importance 

to the banking industry. This includes 

extensive and ongoing analysis of the 

economy and potential risks to the banking 

industry, sectors of that industry, or individual 

financial institutions. Sound economic 

analysis is critical to prudently managing the 

Deposit Insurance Fund and fulfilling the 

FDIC’s deposit insurance mission. It also 

permits the FDIC to focus its supervisory 

efforts on the areas of greatest risk and to 

resolve IDI failures at the least cost to the 

Deposit Insurance Fund. The FDIC’s economic 

analyses are evaluated and discussed on an 

ongoing basis through the interdivisional Risk 

Analysis Center in Washington and 

interdivisional Regional Risk Committees in 

each of the FDIC’s regional offices. 

Much of DIR’s formal research program is 

conducted in collaboration with the academic 

community through the Center for Financial 

Research (CFR), which was established in 2004. 

The purpose of the CFR’s research program is 

to expand knowledge and understanding and 

to prompt discussion among the FDIC’s many 

stakeholders on issues affecting the banking 

system. The research focuses on banking 

industry developments, risk measurement and 

management methods, regulatory policy, and 

related topics. Research findings are 

disseminated through meetings of the 
35 | Page

Advisory Committee on Community Banking 

and the Advisory Committee on Economic 

Inclusion, CFR Working Papers, FDIC Staff 

Studies, survey reports, articles in 

independent, peer-reviewed professional 

journals, and presentations at professional 

and academic conferences and other events. 

Completed studies can be found on fdic.gov.

Other FDIC divisions and offices also 

continually perform research, program 

analysis, and evaluation activities both to 

assess their organizational performance and to 

identify program and process improvements 

that would enhance their effectiveness in 

meeting strategic and annual goals and 

objectives, and employee perspectives are 

collected and analyzed through the annual 

Federal Employee Viewpoint Survey. Research 

and analysis are often shared across divisions 

and offices in a consultative process and are 

used operationally to inform organizational 

learning, program management, and 

performance management. In addition, the 

Office of Program Audits and Evaluations, in 

the FDIC’s independent Office of Inspector 

General, conducts program evaluations and 

performance audits to assess the effectiveness 

and efficiency of FDIC programs and 

operations. The Office of Risk Management 

and Internal Controls also performs 

independent audits and evaluations of FDIC 

programs and operations to ensure that they 

are operating efficiently and effectively and 

accomplishing their intended objectives. 

Program evaluations are collaborative efforts 

that may involve management and staff from 

multiple divisions and offices. 

Data Management and Governance

The FDIC seeks to manage its data as a 

corporate resource. This is fundamental to 

empowering FDIC staff at all levels of the 

organization to perform their responsibilities. 

In 2020, the FDIC appointed a new Chief Data 

Officer (CDO) and launched the Enterprise Data 

Governance Group to develop an enterprise 

data management strategy and implement a 

new enterprise data governance framework. 

In conjunction with that initiative, the CDO is 

leading a corporate-wide effort to establish a 

target data architecture for a new cloud data 

platform, implement a data literacy program, 

and create an enterprise data catalog. The 

CDO is also collaborating with the FDIC’s 

Corporate University (CU) to develop training 

for employees on the use of these new tools. 

CU provides employees in all disciplines with 

career-long learning and development 

opportunities to equip them to meet the 

Corporation’s current and future skills needs, 

including data analysis skills that are central to 

each of the FDIC’s major business programs.

The FDIC is also pursuing data security 

initiatives to protect confidential and sensitive 

data from unauthorized access or misuse. The 

FDIC’s multi-year IT Modernization Program 

initiated in 2020 includes initiatives intended 

to mature the Corporation’s cybersecurity 

capabilities to ensure the continued 

confidentiality, availability, and integrity of 

FDIC systems and data. The FDIC will continue 

to implement current and emerging federal 

information security regulations, policies, and 

practices, including those governing the 
36 | Page

collection, access, and use of data generated 

by the FDIC in the execution of its mission.

Technology and Innovation

The FDIC established the FDIC Tech Lab 

(FDITECH) in 2019 to promote experimentation 

with innovative emerging technologies and, 

where appropriate, accelerate their adoption 

by both FDIC-insured and supervised 

institutions and by the FDIC. Many initiatives 

being pursued by FDITECH in partnership with 

FDIC business divisions hold the promise of 

increasing the FDIC’s analytical capabilities. 

For example, the FDIC is experimenting with 

the application of artificial intelligence and 

machine learning technologies to its bank 

examination reports to identify cross-cutting 

risks. It is also planning to pilot a number of 

third-party proposals that emerged from a 

Rapid Phased Prototyping competition 

completed in 2021 that would provide the FDIC 

access to supplemental bank information (e.g., 

loan information) that could facilitate 

continuous offsite monitoring and analysis of 

risk in individual institutions.