The OCC last week proposed revising its guidelines establishing standards for recovery planning by certain large insured national banks, federal savings associations, and federal branches. The OCC said the proposal would not apply to supervised institutions with less than $100 billion in average total consolidated assets. Comments are due Aug. 2.
The proposal would expand recovery planning guidelines to apply to insured national banks, federal savings associations, and federal branches with at least $100 billion in assets (current guidelines generally apply to banks with average total consolidated assets of $250 billion or more), incorporate a testing standard for recovery plans, and clarify the role of nonfinancial risk—including operational and strategic risk—in recovery planning.