RECOVERY PLANNING FOR US BANKS

The OCC has announced a Notice of Proposed Rulemaking (essentially a RFC) to establish enforceable guidelines for recovery planning. Such plans if implemented would impact insured national banks and savings institutions and FDIC insured branches of foreign banks with assets equal to or greater than $50 billion. The comment period will end February 16th, 2016.  

Recovery plans typically include triggers as well as qualitative and qualitative indicators of the risk or stress that should be escalated to the board of directors and senior management that would proceed a threat to critical operations of the bank, including failure.  The recovery plan should also include credible options that would be taken to restore the final strength of the financial institution improve viability. Under the proposal, the board of directors shall review and approve the recovery plan at least annually or more often if changes are needed. Such plans are subject to review and assessment by OCC examiners for appropriateness.  More information can be found on recovery planning for US banks here:  http://www.occ.gov/news-issuances/bulletins/2015/bulletin-2015-50.html

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