The OCC has finalized a proposal establishing enforceable standards requiring national banks and other institutions under its authority with assets over $50 billion to ensure resilience under operational risks such as cyber-attacks as well as their resolvability in the event these or other risks threaten viability. Although significant investment is required to meet the BHC and IHC resolution-plan requirements and these additional investments, and staff may reduce the burden of meeting these OCC requirements to some extent, the OCC is emphatic: entities under its authority must meet these standards. Often, these go farther than those addressed in resolution-plan and stress-test standards, making the OCC’s requirements unique in terms of their requirements that banks go beyond capital and liquidity resilience, but also take fully into account operational, succession, reputational, and regulatory factors. A key issue for the OCC is the resilience and resolvability of the national bank, which must be demonstrated even if the national bank is the principal activity in a BHC with FRB-approved living wills and stress tests.
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