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December 17, 2025

The OCC’s Proposal to Eliminate Recovery Planning Would Make Large Bank Failure More Likely

WASHINGTON, D.C.— Phillip Basil, Director of Economic Growth and Financial Stability at Better Markets, issued the following statement upon filing of a comment letter to the Office of the Comptroller of the Currency in regard to its proposal to rescind its guidelines around recovery planning for large banks:

“The OCC’s proposed elimination of the recovery planning process for large banks—a preparedness process that is critical to preventing failures and maintaining financial stability—after ten years of support clearly shows that the OCC is now putting the public interest aside and emphatically supporting and pursuing the industry’s interest. There was one important and obvious commonality among large banks that failed in the 2008 crash and in the 2023 banking stress: those banks did not do recovery planning and were not prepared for the crisis situations that led to their failure. Removing the recovery planning process ensures all large banks will be unprepared, making their failures under stress much more likely.

“The proposal is a complete about-face from the OCC’s long history of supporting the recovery planning process, and the OCC has issued the proposal without any valid justification. The comment letter urges the OCC to rescind its proposal instead of the recovery planning process and to maintain a key requirement that promotes a more stable and resilient financial system and protects US taxpayers from the costs of massive bailouts.”

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Better Markets is a non-profit, non-partisan, and independent organization founded in the wake of the 2008 financial crisis to promote the public interest in the financial markets, support the financial reform of Wall Street and make our financial system work for all Americans again. Better Markets works with allies—including many in finance—to promote pro-market, pro-business and pro-growth policies that help build a stronger, safer financial system that protects and promotes Americans’ jobs, savings, retirements and more. To learn more, visit www.bettermarkets.org.

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