2025 Regulatory Summit

Planning Time For Recent Failures

Most bank closings since 2023, were driven by liquidity or fraud issues resulting in compressed timelines.

Bank Name Year

Failure Cause Suspected Fraud Suspected Fraud Suspected Fraud

Days

2025

Santa Anna National Bank

18

Pulaski Savings Bank 2025

22 14

The First National Bank of Lindsay 2024 Republic First Bank dba Republic Bank 2024

Insolvency

116

Citizens Bank 2023

Suspected Fraud Suspected Fraud

32

Heartland Tri-State Bank 2023

4

First Republic Bank 2023 Signature Bank 2023 Silicon Valley Bank 2023

Liquidity Liquidity Liquidity

51

2 1

11

Potential Impact of Compressed Resolution Preparation Timeline

Insufficient time to gather necessary bank information.

Limited time for potential acquirers to perform thorough due diligence.

Limited planning time to identify and mitigate risks.

Bank staff overwhelmed with competing requests.

Limited opportunities to coordinate closing activities with chartering authorities and/or acquiring institutions.

Sequential tasks become stacked resulting in the inability to complete key milestones.

Inadequate time to secure and deploy appropriate closing resources.

Need to develop multiple contingency plans given evolving circumstances.

12