Analysis
Analysis: No formal deficiency does not mean no substantive concern. The American Express letter identifies significant uncertainty in coordinating a single buyer across bank receivership and holding-company bankruptcy proceedings. It asks AmEx to review that strategy for its July 1, 2028 targeted plan and consider alternatives if the obstacles cannot be addressed. Comptroller Jonathan Gould voted against the AmEx feedback, criticizing the process and the consequences of concerns that are not classified as shortcomings. His dissent does not reverse the joint agency findings. For bank risk teams, distinguish formal classifications from forward-looking supervisory expectations.
What remains uncertain
These are resolution-plan assessments, not a guarantee of successful resolution, a public supervisory rating or termination of an unrelated enforcement order. The AmEx letter and Gould’s objections describe different perspectives on the same review.
Sources
- FDIC — resolution-plan feedback for 15 banking organizations ↗Official release
- Federal Reserve/FDIC — American Express feedback letter ↗Official release · PDF
- Federal Reserve/FDIC — BNP Paribas feedback letter ↗Official release · PDF
- OCC — Comptroller explains vote against AmEx feedback ↗Official release