The OCC finalized the repeal of its recovery planning guidelines, which required large banks to maintain detailed playbooks for financial stress scenarios. The agency concluded that “prescriptive planning activities do little to improve their ability to manage through stress.” While this applies primarily to banks over $100 billion, it signals a regulatory environment that adds more weight to management discretion than rigid, prescriptive rules and planning requirements.
What you should do: Even if your institution isn’t at the mega $100 billion range, this is a reminder to have a clear, practical playbook for liquidity stress, cyber events, and other disruptions.
Source: https://www.occ.treas.gov/news-issuances/bulletins/2026/bulletin-2026-10.html