OCC Plans to Scrap Recovery Rules for Big Banks
Published Date: 11/18/2025
Proposed Rule
Summary
The OCC is planning to cancel the rules that made certain big banks and savings associations create recovery plans. This change affects large insured national banks, federal savings associations, and federal branches, and it means less paperwork and planning for them. Comments on this change are open until December 18, 2025, so stakeholders have time to weigh in before it takes effect.
Analyzed Economic Effects
4 provisions identified: 4 benefits, 0 costs, 0 mixed.
OCC to Remove Bank Recovery Plan Rule
The OCC proposes to remove appendix E of 12 CFR part 30, which would end the Guidelines that require certain banks to prepare recovery plans. The Guidelines currently apply to insured national banks, insured Federal savings associations, and insured Federal branches with average total consolidated assets of $100 billion or more.
Large Paperwork Burden Eliminated
The current Guidelines apply to 21 respondents and impose a total paperwork burden of 672,360 hours, or about 32,017 hours per respondent. If the rescission is finalized, the OCC will seek discontinuance of OMB Control Number 1557-0333 for this information collection.
Estimated Private-Sector Savings ~$20M
The OCC estimates that rescinding the Guidelines will produce cost savings of approximately $20 million for the private sector. The OCC notes this amount is below the UMRA threshold of $187 million (adjusted) for a federal mandate.
Small Entities Not Affected
The OCC certified under the Regulatory Flexibility Act that rescinding appendix E will not have a significant economic impact on a substantial number of small entities because the Guidelines apply only to institutions with average total consolidated assets of $100 billion or more. Therefore, no small entities supervised by the OCC would be impacted.
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