The OCC is proposing enforceable guidelines detailing how national banks, federal savings associations, and insured branches of foreign banks subject to the OCC with assets over $50 billion are to ensure they can quickly recover under stress scenarios, especially operational ones such as cyber-attack. The OCC has retained discretion to impose its recovery guidelines to otherwise-exempt institutions, although it emphasizes that these would never include community banks.  Boards and management would need to justify complex organizational/legal structures, putting pressure on them to simplify operations likely to build on efforts already underway in resolution planning.   

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