OCC Axes Big Bank Recovery Plans, Eases Stress Test Burdens
Published Date: 4/1/2026
Rule
Summary
Starting May 1, 2026, the OCC is scrapping the recovery planning rules for certain big banks and federal savings associations. This means these banks no longer have to follow specific recovery plan standards designed to help them bounce back from financial stress. The change aims to cut down on extra paperwork without affecting safety or costs.
Analyzed Economic Effects
4 provisions identified: 4 benefits, 0 costs, 0 mixed.
Large Banks: Recovery Plans Scrapped
Starting May 1, 2026, the OCC is rescinding the recovery planning Guidelines at 12 CFR part 30, appendix E. Banks with average total consolidated assets of $100 billion or more will no longer be required to develop and maintain formal recovery plan documentation, and the OCC will no longer examine those documents.
Estimated $20M Annual Savings
The OCC states the rescission will result in approximately $20 million of annual cost savings to covered banks. This savings comes from reduced compliance, documentation, and examination burdens tied to the rescinded Guidelines.
Small Entities Not Affected
The OCC certified under the Regulatory Flexibility Act that the rescission will impact no small entities because the Guidelines only apply to institutions with average total consolidated assets of $100 billion or more. Small banks and savings associations (as defined by the Small Business Administration) will not be affected.
Contingency Funding Not Codified
The OCC declined to codify the Contingency Funding Guidelines. The agency nonetheless expects all banks to maintain formal contingency funding plans that consider a range of stress scenarios and will continue to review and supervise contingency funding planning activities.
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Key Dates
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