Rescission of OCC Recovery Planning Standards for Large Insured National Banks and Federal Savings Associations

The Office of the Comptroller of the Currency (OCC) is rescinding its previously established guidelines that required certain large insured national banks, insured federal savings associations, and insured federal branches to maintain formal recovery planning frameworks. These guidelines, originally introduced to strengthen the resilience of large financial institutions, mandated that covered entities develop and maintain comprehensive recovery plans to address severe financial stress scenarios without requiring government support. The rescission eliminates a regulatory requirement that applied to institutions with average total consolidated assets of $50 billion or more. Covered entities were previously obligated to identify recovery options, establish triggers for plan activation, and regularly test and update their recovery frameworks. With this rule, those obligations are removed from the OCC's regulatory framework. This action reflects a broader regulatory deregulatory posture under the current administration, aiming to reduce compliance burden on large banking institutions. The OCC has determined that existing supervisory tools and other applicable regulatory requirements provide sufficient oversight of large institutions' financial resilience without the dedicated recovery planning guidelines. The effective date of this rescission is April 1, 2026, after which covered institutions are no longer required to maintain or submit recovery plans under the OCC's guidelines, though other applicable federal and international recovery and resolution planning requirements may still apply.

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