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OCC issues final guidelines for large bank recovery planning

The OCC releasedfinal guidelines establishing standards for recovery planning by insuredOCC-regulated national banks, insured federal savings associations, and insuredfederal branches of foreign banks with average total consolidated assets of $50billion or more.

Under thefinal rule and guidelines — which take effect on Jan. 1, 2017 — OCC examinerswill assess a covered institution's ongoing recovery planning as part of itsregular supervisory activities.

At leastannually, a covered institution's management should review the bank's recoveryplan, and its board should review and approve the plan, according to theguidelines. The recovery plan should also be integrated into the institution'srisk governance framework, and should include triggers alerting the institutionto the risk or presence of severe stress.

The OCC has scheduled a phased in compliance period. Acovered bank with between $100 billion and $750 billion in average totalconsolidated assets on the effective date should comply within 12 months; a bankwith between $50 billion and $100 billion in assets should comply within 18months; and a bank with less than $50 billion in assets on the effective date,which subsequently becomes a covered bank, should comply within 18 months ofbecoming a covered bank.