ABA offered feedback on the OCC’s proposed guidelines on recovery planning for the financial institutions it regulates with assets of more than $50 billion. As proposed, each covered bank would be expected to develop and maintain a recovery plan appropriate for its own risk profile, size, activities and complexity.
ABA pointed out that many banks are already putting significant efforts into developing their own recovery plans, and that the proposed OCC guidelines would require banks to devote additional time and resources to consolidating, synthesizing and reporting the requested information in the required format. Given that, covered banks should be able to use their existing resources to the greatest extent possible when meeting the OCC guidelines and adapting their existing recovery plans to their new standard, ABA said.
The association also called on the OCC to clarify its intentions concerning the implementation of the guidelines, and ensure that sufficient time is allowed for banks to come into compliance. ABA recommended an implementation date of 2018 at the earliest, which would allow for extensive dialogues between banks and examiners.
Read the comment letter.