OCC Guidelines Establishing Standards for Recovery Planning by Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches
Summary
SIFMA and the Bank Policy Institute (BPI) provide comments to the Office of the Comptroller of the Currency (the OCC) on their proposed amendment to its guidelines relating to recovery planning standards for insured national banks, insured federal savings associations and insured federal branches. The recommendations provided are designed so that formal recovery planning is more aligned with the differing risk profiles of the banking organizations that are subject to the Guidelines.
Excerpt
Via Electronic Mail
Legislative and Regulatory Activities Division
Office of the Comptroller of the Currency
400 7th Street SW, Suite 3E–218
Washington, DC 20219
Docket ID OCC–2018–0028
Re: OCC Guidelines Establishing Standards for Recovery Planning by Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches
Ladies and Gentlemen:
The Bank Policy Institute (BPI) and the Securities Industry and Financial Markets Association (SIFMA and, together, the Associations) appreciate the opportunity to comment on the Office of the Comptroller of the Currency’s (the OCC) proposed amendment (the Amendment Proposal) to its guidelines relating to recovery planning standards for insured national banks, insured federal savings associations and insured federal branches (the Guidelines).
The Associations believe that:
- it is appropriate that all insured national banks, insured federal savings associations and insured federal branches (banks) with less than $250 billion in average total consolidated assets (total assets) are released from formal recovery planning under the Guidelines;
- the OCC should consider a tailored approach to the application of the Guidelines to banks with more than $250 billion in total assets, similar to the approach being considered for large U.S. banking organizations by the OCC in conjunction with the Board of Governors of the Federal Reserve System (the Federal Reserve) and the Federal Deposit Insurance Corporation (FDIC);
- the OCC should consider moving from an annual to a biennial recovery plan cycle with targeted updates for material changes or events;
- recovery planning standards and feedback should be more transparent in the future and, given the nature of the banks subject to the Guidelines, a supervisory horizontal review of recovery plans may not be appropriate; and
- 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.
These recommendations are designed so that formal recovery planning is more aligned with the differing risk profiles of the banking organizations that are subject to the Guidelines.