The OCC’s Final Guidance for Recovery Planning - Getting Started Guide

In September 2016, the Office of the Comptroller of the Currency issued final guidance for recovery planning, requiring OCC-regulated banking organizations with average total consolidated assets of $50 billion or more to develop recovery plans. Covered banks with at least $750 billion in assets are required to comply by July 1, 2017; covered banks with at least $100 billion and less than $750 billion are required to comply by January 1, 2018; and covered banks with at least $50 billion and less than $100 billion are required to comply by July 1, 2018.

Covington and Ernst & Young LLP have developed this practical guide to help covered banks get started with recovery planning and preparing their inaugural plans for review by the OCC in 2017 and 2018.