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OCC proposes rescinding recovery planning guidelines for large banks


The OCC proposed rescinding its recovery planning guidelines for certain large banks.

October 28, 2025 / By ICBA

The OCC seeks comment on a proposal to rescind its recovery planning guidelines for certain large banks.

Details: The recovery planning guidelines in the OCC's regulations apply to insured national banks and federal savings associations with at least $100 billion in assets. Covered institutions must develop a plan that identifies triggers and options for responding to a wide range of stress scenarios. The plan should enable the institution to maintain market confidence without relying on extraordinary government support.

More: The FDIC's resolution planning requirements would not be impacted by this proposal. Acting Chairman Travis Hill has stated the FDIC may propose some changes to its resolution rules.

Comment Period: Comments from the public are due 30 days from the date of publication in the Federal Register.

Fed Action: The Federal Reserve last week requested comment on proposals to enhance the transparency and public accountability of its annual stress test for large banks.

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