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Associations File Comment Letter to the OCC Responding to Its Part 30 Large Bank Recovery Plan Guidance

The Clearing House (TCH), SIFMA, and the FSR (Associations) filed a comment letter responding to the OCC’s proposal for formal Part 30 guidelines on large bank recovery planning requirements. Specifically, the OCC’s proposal would require any insured national bank, insured Federal savings association, or insured Federal branch of a foreign bank with average total consolidated assets of $50 billion or more to develop a recovery plan that describes options for responding to stress events. In the letter, the Associations write that: (i) the OCC should clarify banks’ ability to leverage content from capital plans, contingency funding plans, resolution plans, and parent company recovery plans; (ii) operational stress scenarios should only be relevant to recovery planning to the extent they will cause substantial financial distress to a bank if uncorrected, and recovery options should focus on restoring the bank’s financial strength; (iii) the guidelines should not require management and the board to recommend changes to the bank’s organizational and legal structure every year; (iv) the final guidelines should be tailored for smaller or less complex banks; (v) the final guidelines should clarify that recovery plans are not expected to be as detailed or lengthy as resolutions plans; (vi) each bank should have the discretion to determine when during the calendar year its recovery plan should be finalized, approved by its board, and made available to examiners; and (vii) the effective date of the guidelines should provide banks with a reasonable period of time to develop their initial plans, and should be staggered to facilitate sound implementation.