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Article March 11, 2026

Resolution planning now reshaping treasury strategy at mid-sized banks

Resolution planning now reshaping treasury strategy at mid-sized banks

Faisal Mohed, Director of Capital Planning & Stress Testing, SVP, Valley BankLinkedIn profile for Faisal Mohed

Recovery and resolution planning is no longer a regulatory formality for mid sized U.S. banks. Treasury leaders are increasingly integrating resolution thinking into liquidity risk management, stress testing, and balance sheet strategy as supervisors focu

Recovery and resolution planning is emerging as a central pillar of balance sheet strategy for mid sized U.S. banks, as regulators shift their focus from static compliance exercises toward operational readiness and demonstrable crisis capabilities.

Faisal Mohed, Director of Capital Planning and Stress Testing at Valley Bank, believes the regulatory environment is forcing treasury and risk teams to rethink how resolution planning connects with day to day financial management.

Institutions with assets between $50 billion and $100 billion are facing particular pressure to integrate these frameworks while managing limited resources.

“Recovery and resolution planning is still often treated as a standalone regulatory exercise,” Mohed said. “But regulators increasingly expect firms to demonstrate credible capabilities around liquidity, management information systems, and operational readiness.”

That expectation is creating new challenges for mid-sized institutions categorized as Group B covered insured depository institutions.

These banks are required to demonstrate operational capabilities comparable to larger institutions, even though they are not obligated to produce the full resolution strategies required of the largest banks.

“Group B institutions must demonstrate credible operational capabilities but they are not required to develop a full resolution strategy or franchise valuation methodology,” Mohed said. “That inevitably creates integration burdens and misalignment across treasury and risk functions.”

The result is that many institutions must build new systems and processes that link liquidity stress testing, collateral management, and reporting frameworks in ways that were not previously required.

“Banks must be able to rapidly mobilize liquidity and produce supporting data during stress,” Mohed explained. “Those capabilities require fairly seamless integration between liquidity stress testing, collateral management, and reporting systems.”

For smaller organizations, that level of operational readiness often requires significant changes to internal infrastructure.

Processes that were originally designed for routine balance sheet management may not be able to support crisis level reporting or operational continuity requirements.

“Many mid-sized institutions effectively have to rewire processes and systems to accommodate crisis focused data reporting,” Mohed said.

Another complication arises from differences between traditional asset liability management frameworks and the metrics used in resolution planning.

Treasury teams typically focus on funding structure, interest rate risk, and balance sheet optimization, while resolution frameworks emphasize liquidity outflows and separability of business units.

“ALM processes and resolution planning often rely on different assumptions,” Mohed said. “Resolution planning places much greater emphasis on liquidity outflows, franchise components, and separability analysis.”

These differences can create friction between regulatory expectations and day to day risk management frameworks.

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