OCC Proposes Rescinding Recovery Planning Standards Guidance
Commentary by Tim Byrne
The Office of the Comptroller of the Currency ("OCC") proposed rescinding its recovery planning guidelines for large insured banks and savings associations.
In the proposed rulemaking, the OCC explained that the recovery planning guidelines establish standards for how large insured banks should prepare to respond to severe financial stress or operational disruptions. Since their initial issuance in 2016, the OCC has periodically revised the guidelines—most recently in October 2024—to adjust the asset threshold for covered banks, add testing requirements, and expand consideration of non-financial risks. The latest amendments took effect on January 1, 2025. (See related coverage.)
The OCC provided the following reasons for its proposal to rescind the guidelines: (i) they impose an unnecessary regulatory burden with limited practical value, requiring extensive documentation that may prove irrelevant in real stress events; (ii) rescission would restore flexibility and control to bank management, allowing risk management to operate as a dynamic, real-time process; (iii) existing supervisory frameworks already address core risk management expectations, rendering the guidelines redundant; and (iv) there is no statutory mandate for recovery planning, making the requirements discretionary and subject to removal.
The OCC also requested feedback on whether to codify existing contingency funding plan expectations.
Comments on the proposal are due within 30 days of its publication in the Federal Register.
Commentary
This is a significant rolling back of a prudential regulatory requirement. This initiative will benefit the largest banks, but it also establishes an expectation that the OCC is thinking seriously about outright repeal of various regulatory requirements. In this regard, in a March 2025 comment letter submitted as part of the EGRPRA regulatory review process, a banking industry trade association had recommended that these guidelines be rescinded. The OCC’s action indicates that the industry’s active participation in the EGRPRA process (the final comment period closed Oct. 23, 2025) may result in further significant changes to the regulatory environment supported by the industry.
Related Articles
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The OCC adopted rule changes to current recovery planning guidelines. The amendments (i) lower the "covered bank threshold," (ii) include a testing requirement and (iii) require the consideration of non-financial risk.
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The OCC proposed rule changes to current recovery planning guidelines, which would (i) lower the "covered bank threshold," (ii) include a testing requirement and (iii) require the consideration of non-financial risk.
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The Office of the Comptroller of the Currency published a new "Recovery Planning" booklet of the Comptroller's Handbook.