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.
You Might Also Be Interested In...
Bank Activities and Structure The FDIC’s Proposed Increase in Deposit Insurance Assessments May Be Based On Incorrect Projections
Bank Liquidity Imposition of SPOE and TLAC Requirements on Large Regional Banks is Unnecessary to Promote Financial Stability
Bank Liquidity Applying Global Bank Resolution Rules to Regional Banks Would Undermine Bipartisan Tailoring Efforts, Increase Costs for Borrowers and Produce No Tangible Public Benefit
Resolution & Recovery Planning Any Major Revamp of Bank Resolution Plan Requirements Should be Done Only Through Rulemaking
Resolution & Recovery Planning Putting “Too Big to Fail” to Rest: Evidence from Market Behavior in the COVID-19 Pandemic
Resolution & Recovery Planning BPI, FSF Comment on FSB Solvent Wind-Down and Resolution Disclosure Consultations
More Posts by This Author
Digital Assets BPI Comments on Treasury Department Review of Digital Assets in Response to Executive Order
Community Reinvestment Act BPI Comments on Federal Banking Agencies’ Community Reinvestment Act Proposal
Bank Liquidity The Bank of England Just Released Its Plan for Getting Smaller. The Fed Could Learn from it.