OCC Rescinds Recovery Planning Guidelines for Large Banks, Citing Regulatory Burden

The Office of the Comptroller of the Currency (OCC) has rescinded its recovery planning guidelines that apply to banks with at least $100 billion in assets, saying this is part of its effort to eliminate unnecessary regulatory burden.

The OCC’s final rule rescinding these guidelines was announced Tuesday (March 31) and will become effective 30 days after its publication in the Federal Register, the OCC said in a Tuesday press release.

“Recovery planning guidelines that require large banks to engage in prescriptive planning activities do little to improve their ability to manage through stress and distract from the real work of running a safe and sound institution,” Comptroller of the Currency Jonathan V. Gould said in the release. “Rescinding these guidelines helps ensure the banks we supervise can focus their resources on serving their customers and communities.”

The OCC said in the release that it expects the institutions it supervises to be well managed and have appropriate risk management processes in place.

According to OCC Bulletin 2026-10 released Tuesday, guidelines rescinded by the final rule are at 12 CFR 30, appendix E.

In addition, the bulletin itself rescinds the “Recovery Planning” booklet of the Comptroller’s Handbook and four OCC Bulletins: 2025-35, 2024-31, 2024-16 and 2018-47.

The OCC announced in October that it proposed rescinding these recovery planning guidelines. The agency said the guidelines, which went into effect Jan. 1, 2025, were unnecessary because the OCC expects these institutions to be well managed and have appropriate risk management processes in place.

“Risk management is a dynamic process that involves real-time responses to the facts and circumstances of a stress event or periods of stress,” the OCC said at the time in a press release. “Banks should routinely assess and adjust their operations to adapt to evolving risk factors and conditions. Relieving covered banks of the obligation to engage in prescriptive recovery planning activities is consistent with the OCC’s ongoing effort to identify and eliminate unnecessary regulatory burden.”

When the OCC announced in October 2024 that it finalized revisions to its recovery planning guidelines effective Jan. 1, 2025, it said in a press release that they were part of the regulator’s effort to “ensure that large banks are adequately prepared for and have developed plans to respond to the financial effects of severe stress, particularly in light of the contagion effects and systemic risks they may impose.”