On Monday, BPI and SIFMA submitted a comment letter to the OCC on its proposal to raise the asset threshold for its national bank recovery planning requirements from $50 billion to $250 billion. The letter offers support for the OCC’s proposal to release banks with less than $250 billion in total assets from the requirements, and goes on to outline the four following recommendations to ensure that formal recovery planning is more aligned with the differing risk profiles of the remaining banks that would be subject to the requirements: (1) the OCC should consider a tailored approach to the application of the requirements to banks with $250 billion or more in total assets; (2) the OCC should consider moving from an annual to a biennial recovery plan cycle with targeted updates for material changes or events; (3) recovery planning standards and feedback should be more transparent in the future, and supervisory horizontal reviews of recovery plans may be inappropriate; and (4) the OCC should immediately clarify that no recovery plans are expected of banks on or after January 1, 2019 if they do not meet the $250 billion total assets threshold.
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