OCC Rescinds Recovery Planning Guidelines for Certain Large Banks

Reference: Bulletin 2026-10

Official publication: Read the full Bulletin 2026-10 on the agency website

On March 31, 2026, the Office of the Comptroller of the Currency issued Bulletin 2026-10 announcing a significant rollback in its formal recovery planning framework for certain large OCC-supervised institutions. The bulletin states that the OCC is rescinding its guidelines establishing standards for recovery planning by certain large insured national banks, insured federal savings associations, and insured federal branches.

Executive Summary

Bulletin 2026-10 communicates that the OCC has adopted final guidelines rescinding the recovery planning standards previously codified at 12 CFR part 30, appendix E. The OCC also rescinded related supervisory materials, including the Recovery Planning booklet of the Comptroller’s Handbook and several prior bulletins tied to the adoption and proposed revision of the recovery planning regime.

For covered institutions, the immediate legal point is straightforward: the specific OCC recovery planning guidelines are being withdrawn, and the final rule becomes effective 30 days after publication in the Federal Register. For institutions with less than $100 billion in average total consolidated assets, the bulletin expressly states that the final rule would not affect them. For larger institutions and federally licensed U.S. branches that had built governance, escalation, and options analysis around appendix E, the harder question is operational rather than textual: what should remain in place as a matter of sound risk governance even after the formal guideline is gone?

That question matters because the rescission does not eliminate broader safety-and-soundness expectations, board oversight duties, liquidity and capital contingency planning needs, or examination scrutiny of resilience planning. In practical terms, institutions should not treat the bulletin as a signal that recovery preparedness is no longer relevant. Instead, they should reassess which program elements were required only because of appendix E and which remain prudent or indirectly necessary under other supervisory expectations.

What the Regulator Issued

The OCC bulletin is available here: OCC Bulletin 2026-10. According to the bulletin, the agency is rescinding the recovery planning guidelines at 12 CFR part 30, appendix E. The bulletin also identifies related rescissions, including:

• the Recovery Planning booklet of the Comptroller’s Handbook;
• OCC Bulletin 2025-35, the notice of proposed rulemaking;
• OCC Bulletin 2024-31, the final guidelines issuance;
• OCC Bulletin 2024-16, the earlier notice of proposed rulemaking; and
• OCC Bulletin 2018-47, the final revised recovery planning guidelines.

The bulletin further includes an important scope statement for community banks: OCC-supervised banks with less than $100 billion in average total consolidated assets are not affected by the final rule. That statement does not expand obligations for smaller institutions; it confirms that the rescission is directed at the framework that had applied to specified larger entities.

As a legal matter, the bulletin is notable because it does not merely revise the recovery planning standards. It removes the guidelines altogether. That is a materially different regulatory action. Covered institutions should therefore distinguish between program revisions that preserve a core compliance architecture and rescissions that require re-basing the institution’s control environment against remaining applicable authorities.

Why It Matters

First, the rescission changes the formal source of supervisory expectations for recovery planning. Institutions that previously mapped board reporting, trigger frameworks, menu-of-options analyses, and recovery playbooks to appendix E will need to revisit those mappings. Policies and committee materials that still cite the rescinded appendix should be updated in an orderly way to avoid stale legal references and inaccurate control inventories.

Second, a rescission of specific guidelines does not mean examiners will ignore recovery preparedness. Banks and branches remain subject to broader expectations around corporate and risk governance, strategic planning, liquidity risk management, capital planning interfaces, operational resilience, and credible escalation during stress. In other words, the binding hook may have changed, but the supervisory interest in whether management can identify deterioration early and execute credible response options almost certainly has not.

Third, the change raises governance questions for boards and senior management. Some institutions will be tempted to retire recovery planning artifacts immediately. That response may be too aggressive. If a recovery plan, or portions of it, currently serves as the institution’s best integrated framework for stress escalation, management decision-making, interaffiliate coordination, or communication protocols, wholesale elimination may create practical control gaps. The better approach is to identify which components were compliance-driven and which components are embedded risk-management tools worth retaining.

Fourth, the bulletin has implications for examination readiness and internal audit. Examiners may reasonably ask how the institution responded to the rescission, whether policies were updated, whether related management information remains fit for purpose, and whether the bank has preserved enough documentation to demonstrate sound contingency governance. Internal audit and compliance testing functions should be prepared to validate that the institution’s post-rescission framework is internally coherent and properly approved.

Finally, institutions operating across multiple regulatory regimes should avoid assuming uniform treatment across agencies or legal frameworks. A banking organization may have recovery, resolution, liquidity, and capital contingency obligations or expectations arising from different sources. The OCC’s action narrows one framework, but it does not erase the need for coordinated enterprise governance.

Practical Action Checklist

1. Inventory all policies, charters, procedures, and board materials that cite 12 CFR part 30, appendix E, or related OCC recovery planning issuances.
2. Determine which recovery planning elements were maintained solely to satisfy the rescinded OCC guidelines and which remain justified by broader risk governance needs.
3. Update legal inventories, regulatory change logs, issue-management trackers, and policy cross-references to reflect the rescission and the effective date structure described by the OCC.
4. Brief the board or the appropriate board committee on the rescission, the institution’s transition plan, and any recommendation to retain selected recovery planning capabilities.
5. Reassess triggers, escalation protocols, and recovery options libraries to determine whether they should migrate into other contingency, liquidity, capital, or enterprise stress governance documents.
6. Review examiner communications and prior matters requiring attention to confirm whether any open supervisory items referenced the now-rescinded framework.
7. Coordinate among legal, compliance, risk, treasury, finance, and internal audit so the institution presents a consistent post-rescission governance model.

Open Questions and Watch Items

One open question is how OCC examination teams will recalibrate expectations in practice after the rule becomes effective. The bulletin clearly rescinds the guidelines, but institutions should expect supervisors to continue evaluating whether management can identify stress, escalate promptly, and execute credible corrective actions. The examination vocabulary may shift even if the underlying resilience concerns do not.

Another watch item is documentation discipline during transition. A bank that removes formal recovery planning documents without clearly reallocating responsibilities may create ambiguity in decision rights, reporting lines, and stress governance. That ambiguity can become a supervisory problem even when a specific rule has been withdrawn.

Institutions should also watch for any follow-on OCC commentary, examination guidance, speeches, or handbook revisions addressing how firms should think about recovery capabilities after the rescission. The bulletin answers the narrow legal question of appendix E’s status. It does not fully answer what a well-governed institution should keep, consolidate, or retire in response.

My Law Tampa publishes this memorandum for attorneys, compliance officers, and financial institutions tracking U.S. banking regulatory developments and their practical governance consequences.

This memorandum is informational only, is not legal advice, and does not create an attorney-client relationship with My Law Tampa.

Source Materials

• Official publication: Bulletin 2026-10
• Regulator archive: OCC memo archive
• Memo library: browse the full regulatory memo archive
• Related memo: OCC Proposes New AML/CFT Program Requirements: A Strategic Shift for National Banks
• Related memo: OCC and FDIC Codify Prohibition on Reputation Risk in Supervisory Actions
• Related memo: OCC Bulletin 2026-8: Proposed Revisions to Regulatory Capital Rules