The Office of the Comptroller of the Currency's unexpected move to require the largest banks to develop a "recovery plan" has raised questions about why the agency is moving now and how its mandate differs from regulatory requirements for institutions to develop "living wills."

The intent of the living wills was to make financial institutions be more forward thinking, and they found they're not necessarily getting that through with the living wills," said Tristram Wolf, an associate in the consumer financial services group at Ballard Spahr. "And so this [OCC guidance] is a doubling-down or an attempt to push that approach even further to make banks of smaller size think about their operation in terms of recovering from a financial crisis."

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