The Office of the Comptroller of the Currency ("OCC") proposed amendments to guidelines relating to recovery plans for large insured national banks, federal savings associations and federal branches.

The proposed amendments would (i) increase the average total consolidated asset threshold for banks subject to the guidelines to $250 billion and (ii) decrease the time banks have to comply with the guidelines to 12 months. These changes would cause the number of banks subject to the requirements to fall from 25 to 8. If adopted, the proposed guidelines would have an effective date of October 19, 2018.

The OCC is requesting comments on the proposed revisions to the guidelines and on the proposed effective date. Comments must be submitted by November 5, 2018.

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