OCC Rescinds Recovery Planning Requirements for Banks With at Least $100 Billion in Assets

Recovery planning requirements called for large banks to prepare in advance to restore capital, liquidity and operations under severe stress, reducing the risks of failure and financial contagion. In 2024, the U.S. Office of the Comptroller of the Currency expanded the scope to banks with average consolidated assets of at least $100 billion, with the requirements taking effect on January 1, 2025.

The OCC issued a final rule on March 31, 2026, rescinding those recovery planning guidelines. The rule was published in the Federal Register on April 1 and takes effect 30 days after publication. The OCC said plans based on hypothetical scenarios had not effectively helped banks navigate crises and that rescission would ease compliance burdens. Banks must still maintain risk-management and emergency-funding arrangements, while their resolution-planning obligations for handling failures remain unchanged.