OCC finalizes rule rescinding recovery planning guidelines
On March 31, the OCC finalized a rule, proposed in October 2025 (covered by InfoBytes here), rescinding its recovery planning guidelines (Appendix E to 12 CFR Part 30) for certain large insured national banks, federal savings associations, and insured federal branches with average total consolidated assets of $100 billion or more. The OCC adopted the proposed rule without changes. The agency asserted that the guidelines imposed unnecessary regulatory burden, finding that recovery planning documentation was “scenario-dependent or otherwise conjectural” and “irrelevant or of limited utility” when a covered bank faced stress. The OCC estimated the rescission would produce approximately $20 million in annual cost savings for covered banks.
The agency also declined to codify the contingency funding plan expectations outlined in the Interagency Policy Statement on Funding and Liquidity Risk Management, on which the agency had sought comment in the proposal. The OCC stated it would continue to review those guidelines and still expects all banks to maintain formal contingency funding plans that consider a range of stress scenarios. The rule is effective May 1.