Final rule; correction. The Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) published a final rule in the Federal Register of September 1, 2026, to define the term "unsafe or unsound practice" for purposes of section 8 of the Federal Deposit Insurance Act and to…
Why this matters
The document is a correction notice to a final rule published September 1, 2026 (FR Doc. 2026-17823). The OCC and FDIC are correcting the agency docket number from an incorrect citation to OCC-2025-0174.
The Office of the Comptroller of the Currency (OCC) recently updated the structure and references of the OCC Cybersecurity Supervision Work Program (CSW) used by examiners. As cyberattacks evolve and as banks adopt various standardized tools and frameworks to assess cybersecurity preparedness, the OCC continues to…
Why this matters
This is an administrative update to the OCC's Cybersecurity Supervision Work Program that realigns its structure with the updated NIST Cybersecurity Framework. The bulletin explicitly states that no new procedures were added, no new regulatory expectations were established, and banks are not required to use this work...
The Office of the Comptroller of the Currency (OCC) today released enforcement actions for September 2026.
Why this matters
This is a standard OCC news release announcing two Orders of Prohibition against individual employees (former bankers) for criminal conduct (embezzlement and unauthorized account debits).
Joint interim final rule and request for comments. The OCC, Board, and FDIC (collectively, the Agencies) are jointly issuing and requesting public comment on an interim final rule to implement section 903 of the 21st Century ROAD to Housing Act. The interim final rule raises the asset threshold for certain supervised…
Why this matters
This is a joint final interim rule issued by OCC, Federal Reserve, and FDIC implementing statutory amendments to the Federal Deposit Insurance Act. It raises the asset threshold from $3 billion to $6 billion for qualifying insured depository institutions to qualify for 18-month (rather than 12-month) on-site...
The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (the Board) and the Federal Deposit Insurance Corporation (the FDIC, and collectively, the agencies) are issuing a statement to provide clarity on their risk-based supervision of certain services provided by core…
Why this matters
This is a joint statement from OCC, Federal Reserve, and FDIC providing clarity on supervisory approach to third-party core service providers used by community banking organizations.
The Office of the Comptroller of the Currency today continued to empower community banks and reduce their burden with a proposal to tailor third-party risk management to actual risk, and by providing greater clarity regarding supervision and enforcement of core service providers.
Why this matters
This is a policy proposal from the OCC (U.S. banking regulator) that introduces tailored third-party risk management guidance and clarifies supervision of core service providers for community banks.
Agencies Seek Comment on Proposed Third-Party Risk Management Guidance and Issue Statement on Community Bank Engagement with Core Service Providers Today the Federal Deposit Insurance Corporation, the Federal Reserve Board, the National Credit Union Administration, and the Office of the Comptroller of the Currency…
Why this matters
This is a formal consultation (OCC Bulletin) issued jointly by four federal banking agencies (OCC, Federal Reserve, FDIC, NCUA) proposing revised guidance on third-party risk management. The guidance applies broadly to national banks, federal savings associations, federal branches/agencies, and community banks.
Today the Federal Deposit Insurance Corporation, the Federal Reserve Board, the National Credit Union Administration, and the Office of the Comptroller of the Currency (collectively, the agencies) requested comment on proposed guidance to assist financial institutions with managing risks associated with third-party…
Why this matters
This is a multi-agency (FDIC, Federal Reserve, NCUA, OCC) consultation requesting comment on proposed guidance to replace existing third-party risk management rules. The update directly addresses supervisory expectations for managing third-party relationships and core service provider engagement.
The Office of the Comptroller of the Currency today published an interim final rule that raises the asset threshold for certain supervised institutions with less than $6 billion in total assets to qualify for an 18-month on-site examination cycle, pursuant to the 21st Century ROAD to Housing Act.
Why this matters
This is an interim final rule that materially affects examination frequency and compliance obligations for a defined cohort of smaller banks. The asset threshold increase from $3B to $6B expands the population eligible for 18-month exam cycles, representing a concrete regulatory relief measure with operational and...
The federal bank regulatory agencies today issued an interim final rule increasing the number of community banks eligible for an 18-month exam cycle.
Why this matters
This is a final interim rule issued jointly by three federal banking agencies (OCC, Federal Reserve, FDIC) that increases the asset threshold for 18-month exam cycles from $3B to $6B, directly affecting examination frequency and supervisory burden for community banks and credit unions.
The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation have published an interagency interim final rule amending the regulations governing eligibility for the 18-month on-site examination cycle, pursuant to the 21st…
Why this matters
This is a binding interim final rule from the OCC (interagency with Fed and FDIC) that materially changes examination frequency requirements for banks under $6B in assets meeting 1-2 ratings and other criteria. The asset threshold expansion is substantive and affects a significant population of community banks.
The Office of the Comptroller of the Currency (OCC), jointly with the Financial Crimes Enforcement Network (FinCEN), the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the National Credit Union Administration, issued answers to frequently asked questions (FAQ) related…
Why this matters
This is a multi-agency FAQ bulletin providing authoritative clarification on how banks must treat state-issued mobile driver's licenses and other verifiable digital credentials under BSA/AML CIP requirements.
On September 2, 2026, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network (FinCEN), and the National Credit Union Administration issued a statement to clarify confidentiality…
Why this matters
This is a joint regulatory statement from OCC, Federal Reserve, FDIC, FinCEN, and NCUA that clarifies the scope and application of Bank Secrecy Act confidentiality requirements for SARs.
The Office of the Comptroller of the Currency (OCC) today released a list of Community Reinvestment Act (CRA) performance evaluations that became public during the period of August 1, 2026, through August 31, 2026.
Why this matters
This is a standard OCC news release announcing the public disclosure of Community Reinvestment Act performance ratings for a cohort of national banks and federal savings associations.
Final rule. The Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) are adopting a final rule to define the term "unsafe or unsound practice" for purposes of section 8 of the Federal Deposit Insurance Act and to revise the supervisory framework for the issuance of…
Why this matters
This is a final rule (Document 2026-17823, 91 FR 56004) jointly issued by the OCC and FDIC that codifies a regulatory definition of 'unsafe or unsound practice' under section 8 of the Federal Deposit Insurance Act and revises supervisory frameworks for issuance of Matters Requiring Attention (MRAs).
Notice of proposed rulemaking. The Office of the Comptroller of the Currency (OCC) proposes to revise the supervisory framework for the issuance of matters requiring attention (MRAs) in response to violations of laws or regulations and for addressing violations for which the OCC does not take an enforcement action or…
Why this matters
This is a Notice of Proposed Rulemaking (NPRM) from the OCC that would materially revise the supervisory framework for addressing violations of banking laws and regulations. The proposal introduces a new categorical distinction (substantive vs.
The Office of the Comptroller of the Currency (OCC) today released its schedule of Community Reinvestment Act (CRA) evaluations to be conducted in the fourth quarter of 2026 and the first quarter of 2027.
Why this matters
This is a standard OCC administrative announcement of the Community Reinvestment Act evaluation schedule for Q4 2026 and Q1 2027. It informs banks when they will be evaluated and invites public comment, but contains no new rules, guidance, or enforcement actions.
The Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking to refine the standard for the issuance of matters requiring attention (MRA) in response to violations of laws and regulations (12 CFR 4.92). The proposed rule would establish two categories of violations: "substantive…
AI Analysis
On August 27, 2026, the OCC proposed amending 12 CFR 4.92 to distinguish substantive violations from technical violations and to restrict violation-based MRAs to substantive violations. The proposal would raise the practical threshold for an MRA while preserving examiner authority to require correction of technical violations; independent commentary characterizes the broader supervisory direction as a shift toward material financial risk, legal violations, and more standardized supervisory communications.
Key dates
2026-08-27
The OCC issued Bulletin 2026-42 announcing the notice of proposed rulemaking.
Suggested considerations
Compliance teams may wish to inventory open and recently closed MRAs arising from alleged legal or regulatory violations and assess whether each matter would satisfy one or more of the proposed substantive-violation criteria.
Firms should consider strengthening documentation linking examination findings to duration, frequency, systemic characteristics, financial-condition effects, books-and-records impacts, customer harm, restitution, or insider misconduct.
Banks may wish to separate remediation plans for legal or regulatory violations from broader supervisory enhancements, because the proposal would limit examiner authority over technical violations to directing correction of the violation itself.
Compliance and examination-management teams should consider preparing comments or internal positions on the undefined terms more than minimal, systemic, pattern, and meaningfully impact, including how those terms should be applied to isolated but high-severity events.
Management may wish to review escalation thresholds so that technical-violation treatment does not result in under-escalation of recurring findings that could become systemic or satisfy the proposed substantive criteria.
Banks should monitor the Federal Register publication of the notice of proposed rulemaking and calculate the 30-day comment period from that publication date rather than from the OCC bulletin date.
Legal and regulatory-change teams may wish to assess this proposal alongside the OCC-FDIC final rule and related supervisory reforms concerning unsafe or unsound practices, MRAs, and material financial risk, while treating the proposal as nonfinal until adopted.
What changed
The proposed rule would provide that the OCC may issue an MRA for a violation of a banking or banking-related law or regulation only when the violation is substantive. A violation would be substantive when its nature, duration, frequency, or severity could meaningfully impact the bank or its customers, and at least one of five criteria would need to be met: the violation is systemic or constitutes a pattern; it has had or could reasonably be expected to have a direct, clear, predictable, and more than minimal impact on the bank's financial condition; it has had or could reasonably be expected...
Compliance impact
The proposal is not currently binding, but it could materially change how OCC examination findings involving legal and regulatory violations are categorized, escalated, and remediated. It may reduce MRAs for genuinely minor violations while increasing the importance of evidence showing systemic conduct, recurring patterns, customer harm, financial impact, books-and-records effects, or insider misconduct; the OCC has not proposed eliminating the underlying obligation to comply with applicable law or correct violations.
The Office of the Comptroller of the Currency (OCC) today released two revised Policies and Procedures Manuals (PPM): PPM 5310-3, "Bank Enforcement Actions and Related Matters," and PPM 5400-11, "Matters Requiring Attention."
AI Analysis
On August 27, 2026, the OCC replaced its enforcement and MRA manuals with PPM 5310-3 and PPM 5400-11, aligning OCC supervision with the OCC-FDIC final rule defining unsafe or unsound practices and establishing a risk-based MRA framework. The update raises the practical threshold for MRAs and Section 8 enforcement by emphasizing material financial risk and substantive legal violations, while allowing examiners to communicate lower-level concerns as nonbinding supervisory observations.
Key dates
2026-08-27
OCC issued revised PPM 5310-3 and PPM 5400-11; PPM 5310-3 replaces the May 25, 2023 manual, PPM 5400-11 replaces the February 27, 2026 version, and OCC Bulletin 2023-16 is rescinded.
Suggested considerations
Compliance teams may wish to map open MRAs, enforcement orders, capital directives, and supervisory findings against the new material-harm, Deposit Insurance Fund risk, and substantive-violation thresholds.
Banks should consider reviewing issue-management taxonomies and governance procedures so that MRAs, other violations, and supervisory observations are recorded and escalated according to their distinct consequences.
Board and committee reporting processes may warrant review because supervisory observations do not automatically require board presentation or a corrective-action plan, whereas MRAs and enforcement actions remain subject to formal remediation and validation expectations.
Large and complex banks should consider reassessing whether deficiencies that might previously have produced a community-bank-level supervisory response could receive faster escalation under the revised tailoring framework.
Banks with existing enforcement actions may wish to assess whether their remediation evidence demonstrates substantial compliance with the essential requirements of each order and whether remaining issues are minor and isolated.
Capital management teams may wish to review procedures for the institution of and termination of individual minimum capital ratios under the revised enforcement manual.
Legal and regulatory change teams should monitor Federal Register publication of the joint OCC-FDIC final rule and calculate the actual effective date rather than relying on the bulletin date.
Internal audit and compliance functions may wish to preserve objective factual support for responses to MRAs and other supervisory communications, particularly where the bank believes an issue does not meet the new risk-based threshold.
What changed
Revised PPM 5310-3 replaces the May 25, 2023 version and structures the OCC enforcement framework around escalation, tailoring, and focus. The OCC generally intends to provide banks an opportunity to remediate deficiencies through supervision before initiating a Section 8 enforcement action, although it retains authority to act at any time when legally supportable and warranted.
Compliance impact
The update is likely to reduce the use of MRAs and Section 8 enforcement actions for isolated policy, process, documentation, or other nonfinancial weaknesses that do not meet the new material-risk or substantive-violation standards, but it does not eliminate supervisory discretion or escalation risk.
OCC Acts to Improve Transparency and Consistency to Bank Enforcement and Supervisory Standards OCC issues two revised policies and procedures manuals; proposes amendments to Violations of Laws and Regulations framework WASHINGTON-The Office of the Comptroller of the Currency (OCC) today announced additional actions to…
AI Analysis
On August 27, 2026, the OCC revised its enforcement-action and Matters Requiring Attention (MRA) policies and procedures manuals and publicly released PPM 5400-11 for the first time. The changes implement a risk-based supervisory framework centered on material financial risk and substantive legal violations, while a proposed rule would distinguish substantive violations from technical violations and limit MRAs for legal or regulatory violations primarily to the former.
Key dates
2026-08-27
OCC revised PPM 5310-3 and PPM 5400-11, issued Bulletin 2026-41, and published the proposed rulemaking notice concerning substantive and technical violations. The proposed rule's 30-day comment period begins only upon Federal Register publication.
Suggested considerations
Compliance teams may wish to map open and recently closed MRAs and enforcement actions against the revised material-financial-risk threshold and the stated tailoring factors of capital structure, complexity, activities, and asset size.
Banks should consider documenting objective facts, legal violations, financial-risk consequences, customer impact, duration, frequency, severity, and remediation status supporting the classification and closure of examination findings.
Large and complex banks may wish to reassess escalation risk because the OCC expressly permits enforcement action for practices that might not produce the same response at a community bank.
Banks should consider reviewing corrective-action plans to confirm that each action is directly tied to a specific deficiency and is proportionate to the risk, while preserving evidence of substantial compliance with existing orders.
Compliance teams may wish to distinguish substantive violations from potential technical violations in issue-management inventories, including systemic or repeated conduct, customer restitution, books-and-records impacts, financial-condition effects, and insider misconduct.
Banks should consider monitoring the Federal Register for publication of the proposed rule and calculating the 30-day comment period from that publication date; affected institutions may wish to submit comments on the proposed substantive-versus-technical framework.
Examiners may identify lower-level weaknesses as supervisory observations rather than MRAs; banks should consider maintaining internal governance and risk records for such observations without assuming that the OCC may require a board action plan or track remediation in the same manner as an MRA.
What changed
Revised PPM 5310-3, Bank Enforcement Action and Related Matters, replaces the May 25, 2023 version and emphasizes escalation, tailoring, and focused corrective action. The OCC generally expects to provide a bank an opportunity to remediate deficiencies through supervision before taking an enforcement action under section 8 of the Federal Deposit Insurance Act, although it retains authority to act at any time when legally supportable.
Compliance impact
The final policy changes reduce the likelihood that immaterial procedural, documentation, or nonfinancial weaknesses will independently generate an MRA or enforcement action, but they do not create a general safe harbor for legal violations or weak controls. Risk is likely to remain significant for large or complex banks, systemic or repeated violations, customer harm, inaccurate books and records, insider misconduct, and conduct that materially affects financial condition or the Deposit Insurance Fund.
The OCC and the FDIC issued a joint final rule to define the term "unsafe or unsound practice" for purposes of section 8 of the Federal Deposit Insurance Act and revise the supervisory framework for the issuance of matters requiring attention (MRA) and other supervisory communications.
AI Analysis
On August 27, 2026, the OCC and FDIC issued a joint final rule defining “unsafe or unsound practice” under section 8 of the Federal Deposit Insurance Act and establishing a uniform, narrower standard for Matters Requiring Attention (MRAs). Independent market commentary describes the rule as the first formal regulatory definition of the core supervisory concept and emphasizes its shift toward material financial risk, while creating a less coercive channel for lower-level supervisory concerns.
Key dates
2026-08-27
OCC and FDIC issued the joint final rule through OCC Bulletin 2026-40. The bulletin applies to all OCC-supervised banks; it does not state the Federal Register publication date, effective date, or a firm compliance deadline.
Suggested considerations
Firms should identify the final rule’s Federal Register publication and effective date, because the OCC bulletin itself does not state either date or a compliance deadline, and should monitor OCC and FDIC implementation guidance before relying on any transition treatment.
Compliance teams may wish to inventory open MRAs, supervisory recommendations, enforcement matters, and examination findings and map each item to the final rule’s material-financial-risk, DIF-risk, actual-violation, or already-caused-harm criteria.
Firms should consider separating board-level MRA remediation obligations from discretionary management responses to supervisory observations and documenting why a weakness is treated under one category rather than another.
Risk and compliance functions may wish to enhance evidence files supporting assessments of likelihood, materiality, current and reasonably foreseeable conditions, and impacts on capital, asset quality, earnings, liquidity, and market-risk sensitivity.
Banks should consider documenting how supervisory requirements and remediation plans are tailored to asset size, complexity, activities, capital structure, and other financial-risk factors, particularly where the institution has heightened systemic, concentration, liquidity, or operational complexity.
Legal and compliance teams may wish to distinguish actual violations of banking or banking-related laws and regulations from prudential weaknesses, because an actual violation can support an MRA without separately satisfying the prudent-operation and material-risk test.
Boards and senior management should consider reviewing governance procedures so that MRAs receive required escalation and tracking while supervisory observations are clearly identified as non-binding potential enhancements.
Firms should consider preparing a process for requesting and retaining the objective facts and reasoning underlying an MRA or unsafe-and-unsound-practice determination, as the rule requires examiners to share that basis.
What changed
An unsafe or unsound practice is now defined as a practice, act, or failure to act that is contrary to generally accepted standards of prudent operation and either is likely, if continued, to materially harm the bank’s financial condition or present a material risk of loss to the Deposit Insurance Fund, or has already materially harmed the bank’s financial condition. “Likely” requires more than a merely possible risk; relevant financial-condition effects include impacts on capital, asset quality, earnings, liquidity, and sensitivity to market risk.
Compliance impact
The rule may reduce the scope of MRAs and section 8 enforcement theories for nonfinancial, documentation, process, or reputation concerns that lack a material financial-risk or legal-violation nexus, but it does not eliminate supervisory scrutiny or remediation obligations. Higher-risk banks may face lower materiality thresholds, more granular harm assessments, and more demanding remediation expectations; actual violations remain independently capable of supporting an MRA.
The Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation (the agencies) today issued a final rule that continues their effort to focus examiners' and institutions' attention on material financial risks and compliance with banking and banking-related laws and regulations. The final…
AI Analysis
The OCC and FDIC issued a final rule on August 27, 2026, creating a uniform, risk-based definition of an “unsafe or unsound practice” under Section 8 of the Federal Deposit Insurance Act, 12 U.S.C. § 1818, and establishing standards for Matters Requiring Attention (MRAs) and supervisory observations. The rule raises the threshold for mandatory supervisory action toward material financial risks while preserving MRAs for actual violations of banking or banking-related laws and regulations.
Key dates
2026-08-27
OCC and FDIC issued the final rule and OCC published Bulletin 2026-40 describing its application to OCC-supervised banks.
Suggested considerations
Compliance teams may wish to map existing and anticipated MRAs, enforcement commitments, supervisory recommendations, and examination findings against the new material-financial-risk and actual-violation criteria.
Firms should consider separating board-level corrective-action items from nonbinding supervisory observations and documenting why each issue does or does not meet the MRA threshold.
Risk and compliance functions may wish to update issue-taxonomy and escalation procedures to assess impacts on capital, asset quality, earnings, liquidity, sensitivity to market risk, and the Deposit Insurance Fund.
Banks should consider retaining objective evidence and documented reasoning supporting materiality assessments, including institution-specific factors such as asset size, complexity, activities, and capital structure.
Management and boards may wish to review outstanding policies, process, and documentation findings to determine whether they remain mandatory remediation matters, are better treated as supervisory observations, or independently constitute violations of banking or banking-related law.
OCC-supervised banks should monitor the related examination guidance and assess whether planned lookbacks, independent-consultant requirements, or suspicious-activity review scopes are affected by the revised supervisory approach described in industry reporting.
Firms should track Federal Register publication and calculate the 60-day effective date once publication occurs; the August 27, 2026 announcement date is not itself the effective date.
What changed
An unsafe or unsound practice is now defined as a practice, act, or failure to act that is contrary to generally accepted standards of prudent operation and either, if continued, is likely to materially harm the bank’s financial condition or present a material risk of loss to the Deposit Insurance Fund, or has already materially harmed the bank’s financial condition. Relevant financial-condition impacts include capital, asset quality, earnings, liquidity, and sensitivity to market risk; reputation concerns unrelated to financial condition are excluded.
Compliance impact
The rule is a material change to supervisory and enforcement standards because it is the first formal regulatory definition of “unsafe or unsound practice” and limits mandatory MRAs and corrective direction for matters that do not present material financial risk, except where an actual banking-law violation exists. It may reduce board-directed remediation for lower-risk process or documentation weaknesses, but does not eliminate legal compliance obligations, enforcement exposure for material harm, or remediation requirements for violations required by law.
The Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, National Credit Union Administration, Consumer Financial Protection Bureau, Department of Housing and Urban Development, Department of Justice, and Federal Housing Finance Agency are rescinding the "Interagency Statement on Special…
AI Analysis
On August 25, 2026, the OCC and six other federal agencies rescinded the 2022 Interagency Statement on Special Purpose Credit Programs and OCC Bulletin 2022-3. The rescission removes that guidance as a reference point and emphasizes that special purpose credit programs must not discriminate on prohibited bases under the Equal Credit Opportunity Act, Regulation B, and, where applicable, the Fair Housing Act.
Key dates
2026-04-22
The CFPB published a final rule amending Regulation B provisions concerning special purpose credit programs, including new restrictions applicable to programs offered or participated in by for-profit organizations.
2026-07-21
The CFPB's Regulation B amendments became effective. For-profit special purpose credit programs offered or participated in on or after this date must comply with the amended requirements, including the prohibition on using race, color, national origin, or sex as a common eligibility criterion.
2026-08-25
The seven agencies rescinded the 2022 interagency statement and OCC Bulletin 2022-3, effective immediately. Creditors should no longer rely on those issuances or related guidance.
Suggested considerations
Compliance teams may wish to inventory special purpose credit programs, marketing, eligibility criteria, underwriting policies, written plans, and monitoring practices that were developed or supported by the 2022 interagency statement, OCC Bulletin 2022-3, or related guidance.
Firms should consider reassessing any program that uses race, color, national origin, or sex as a common eligibility criterion, particularly for credit extended on or after July 21, 2026, against 12 CFR 1002.8 as amended.
For-profit creditors may wish to confirm that each written special purpose credit program plan contains evidence of need, explains why the relevant class would not receive credit under the organization's ordinary creditworthiness standards, and supports any eligibility characteristic used by the program.
Compliance teams may wish to remove rescinded guidance from policies, procedures, training materials, legal inventories, product governance documents, and examiner-facing materials, while retaining records needed to explain prior program design and implementation.
Firms should consider reviewing program communications and applicant data practices for potential discrimination or misleading reliance on the rescinded statement, including communications suggesting that protected-class distinctions are broadly authorized.
Banks and credit unions may wish to brief fair-lending, legal, product, underwriting, marketing, and model-risk stakeholders and document the governance decision regarding whether each program should be amended, suspended, or continued under current law.
What changed
The 2022 interagency statement and OCC Bulletin 2022-3 are rescinded, effective immediately, and creditors are instructed not to rely on those issuances or related guidance. The rescission does not eliminate the statutory or regulatory framework for special purpose credit programs under ECOA and Regulation B, including 12 CFR 1002.8; rather, it clarifies that those programs remain subject to applicable fair-lending prohibitions. The agencies specifically identify the prior version of Regulation B referenced by the 2022 statement as having been amended.
Compliance impact
The rescission creates a meaningful fair-lending and product-governance risk for creditors whose special purpose credit programs relied on the withdrawn guidance, although it does not itself create a new statutory prohibition or abolish Regulation B's special purpose credit program provisions. Regulatory and litigation exposure may increase where a program uses prohibited characteristics, lacks the documentation required by amended 12 CFR 1002.8, or treats the rescinded statement as a safe harbor.
The Office of the Comptroller of the Currency (OCC) today released enforcement actions for August 2026.
Why this matters
The content announces the termination of a formal agreement with First National Bank of Pasco dated September 2025, indicating the bank achieved compliance. This is a standard administrative closure notice with no new regulatory requirements, policy changes, or broad applicability.
Comptroller of the Currency Jonathan V. Gould today discussed the Office of the Comptroller of the Currency's (OCC) work under the leadership of President Donald J. Trump and U.S. Secretary of the Treasury Scott Bessent to support the Administration's efforts to grow the economy and lead the global digital currency…
Why this matters
This is a news release documenting a Comptroller speech at an industry event. It contains noteworthy regulatory signals: (1) an eightfold increase in digital asset-related bank charter applications (23 of 40 recent applications), (2) confirmation that a final GENIUS Act rule will be issued by November 2026, and (3)...
The Office of the Comptroller of the Currency (OCC) today released its annual update to the Bank Accounting Advisory Series (BAAS).
Why this matters
This is an informational news release announcing the OCC's annual update to the Bank Accounting Advisory Series. The BAAS is explicitly stated as non-binding interpretive guidance rather than rules or regulations.
The OCC has issued the 2026 edition of the Bank Accounting Advisory Series (BAAS). The BAAS contains staff responses to frequently asked questions from the banking industry and bank examiners on a variety of accounting topics and promotes consistent application of accounting standards and regulatory reporting among…
Why this matters
This is an informational bulletin announcing the 2026 edition of the Bank Accounting Advisory Series (BAAS), which the OCC explicitly states does not represent rules or regulations but rather interpretive guidance on accounting standards.
Notice of proposed rulemaking. The Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) are proposing to amend their Community Reinvestment Act rules by making certain substantive, technical, and process-oriented changes to refocus on the statutory objective of…
AI Analysis
The OCC and FDIC have proposed a new CRA rulemaking that would refocus examinations on lending, tighten how grants and donations qualify for CRA credit, and raise asset-size thresholds that determine bank category and reporting burden. It is a consultation, not a final rule, but it signals a significant shift in CRA compliance priorities and documentation expectations for banks, especially community banks and large institutions making community development grants.
Key dates
2026-08-12
Federal Register publication of the proposed rule at 91 FR 52114
2026-10-13 Deadline
Comments due on the proposed rule
Suggested considerations
Compliance teams may wish to map the proposed changes against current CRA policies, exam procedures, public file practices, and community development grant approval workflows.
Institutions may wish to assess how the proposed asset-size thresholds would change their CRA category and associated data collection, reporting, and evaluation obligations.
Banks making grants or donations may wish to review documentation standards for recipient use of funds, overhead limits, and evidentiary support needed for CRA consideration.
Community development and CRA governance teams may wish to identify which activities would still qualify under the revised CD definitions and performance tests.
Legal and regulatory affairs functions may wish to prepare comments on the proposed lending focus, grant criteria, sunshine requirements, and technical changes to OCC public welfare and corporate activity rules.
Banks subject to CRA-related agreements may wish to verify whether the proposed technical amendments would affect disclosure timing, content, or filing processes.
What changed
['The proposal would amend the OCC and FDIC Community Reinvestment Act rules to make substantive, technical, and process-oriented changes aimed at refocusing the statutory objective on meeting community credit needs and reducing burden, particularly for community banks.', 'The agencies propose to better ensure that community development grants reach intended communities and to provide greater clarity on how to obtain CRA consideration for activities.', 'The OCC and FDIC also propose technical changes to their CRA sunshine rules under the Federal Deposit Insurance Act, which govern disclosure...
Compliance impact
The proposal is potentially high impact because it would alter how banks are assessed under CRA, especially by shifting emphasis toward lending and changing eligibility and documentation rules for community development credit. The agencies describe the changes as reducing unnecessary burden and improving clarity, but they also signal tighter accountability for grants and donations and different supervisory expectations.
The Office of the Comptroller of the Currency continues to prioritize reinvigorating de novo chartering to build a robust, diverse banking system that supports the U.S. economy and commends the Federal Deposit Insurance Corporation for its recent efforts to do the same.
Why this matters
This is a news release announcing policy priorities and regulatory alignment rather than a binding rule or enforcement action. The content specifically addresses de novo chartering processes, application timelines, and encouragement of new entrants including fintech and digital asset-focused entities.
Secretary of the Treasury Scott Bessent and Comptroller of the Currency Jonathan V. Gould today highlighted the Trump Administration's efforts to alleviate regulatory burden on community banks, drive economic growth on Main Street, and protect America's financial system from illicit activity during remarks at the…
Why this matters
This is a news release documenting remarks by the Secretary of the Treasury and Comptroller of the Currency at an industry roundtable. The content conveys policy signals on three themes: (1) regulatory burden reduction for community banks under Dodd-Frank, (2) focus on material financial risk in supervision, and (3)...
Notice of proposed rulemaking. The Office of the Comptroller of the Currency (OCC) is proposing changes to its rules on information disclosure. The proposal would clarify the process for obtaining OCC approval to disclose non- public OCC information and allow for the disclosure of confidential supervisory information…
AI Analysis
The OCC issued a proposed rule on 2026-08-05 to revise 12 CFR part 4 and related rules governing access to and disclosure of OCC information, including a new category of “confidential supervisory information” (CSI) and streamlined FOIA procedures. The proposal matters because it would expand limited information-sharing exceptions while tightening the framework around non-public OCC information, disclosure safeguards, and expedited FOIA processing.
Key dates
2026-08-05
OCC published the proposed rule in the Federal Register (91 FR 50610)
2026-10-05 Deadline
Comment period closes for the proposed rule
Suggested considerations
Compliance teams may wish to map which internal records fall into the proposed CSI category and compare current disclosure controls against the new exceptions and safeguard requirements.
Supervised entities may wish to review any confidentiality agreements and onward-sharing practices to determine whether they would satisfy the proposed conditions for permitted CSI disclosures.
Legal and FOIA teams may wish to update request-handling workflows for expedited processing requests, fee-waiver appeals, and request tracking once the rule is finalized.
Banks and other recipients of OCC information may wish to reassess litigation, government-reporting, and interaffiliate sharing procedures to ensure they align with the revised disclosure framework.
Firms may wish to submit comments by the close of the comment period if the proposed CSI scope, disclosure exceptions, or FOIA procedures would affect their supervisory, legal, or records-management processes.
What changed
The proposal would restructure the OCC’s information-disclosure rules in 12 CFR part 4 and make conforming changes in parts 5, 7, 21, and 163. It would create a new subcategory of non-public OCC information called confidential supervisory information (CSI), clarify when supervised entities and other recipients may disclose CSI without prior OCC approval, and require applicable safeguards and, in some cases, qualifying confidentiality agreements.
The OCC also proposes to permit certain disclosures of CSI in limited circumstances to support business efficiency, government accountability, and...
Compliance impact
This is a significant consultation rather than a final rule, but it signals meaningful changes to how OCC supervisory information may be classified, shared, and protected. The OCC indicates that unauthorized disclosure remains tightly controlled and that the rule would preserve enforcement consequences while adding new, limited disclosure pathways and more structured FOIA handling.
The Office of the Comptroller of the Currency (OCC) is issuing a notice of proposed rulemaking to implement structural and substantive changes to its rules governing the disclosure of OCC information.
AI Analysis
The OCC issued a proposed rulemaking on August 3, 2026 to restructure and revise 12 CFR part 4, which governs disclosure of OCC information. The proposal matters because it would create a new protected category called confidential supervisory information (CSI), broaden limited disclosure pathways, and change FOIA processing and appeal procedures for OCC records.
Key dates
2026-08-03
OCC issued Bulletin 2026-37 announcing the proposed rulemaking on availability of OCC information
2026-10-02 Deadline
Comment period closes 60 days after publication, based on the OCC’s stated deadline formula in the related rulemaking notice
Suggested considerations
Compliance teams may wish to review current controls for handling nonpublic OCC information and identify where internal policies reference the existing 12 CFR part 4 subparts B and C.
Firms may wish to assess whether any current or planned disclosures of supervisory materials could fall within the proposed expanded exceptions for business efficiency, government accountability, or supervisory coordination.
Banks may wish to inventory records that could qualify as aged CSI once the final rule is issued, so they can update retention and disclosure procedures accordingly.
Legal and compliance functions may wish to monitor the final rule and any comment-driven changes to the proposed FOIA expedited-processing and fee-waiver appeal procedures.
Institutions may wish to align employee training with the OCC’s clarified position on unauthorized disclosure and potential criminal referral exposure.
What changed
The proposal would amend the OCC’s disclosure framework in 12 CFR 4 by creating a new subcategory of nonpublic OCC information called confidential supervisory information (CSI). It would modify the prior-approval regime for supervised entities that want to disclose CSI by expanding exceptions for business efficiency, government accountability, and supervisory coordination, while adding safeguards around those exceptions.
The OCC also proposes to provide for the release of certain aged CSI, which would create a time-based disclosure concept not described in the current rule.
Compliance impact
The OCC describes the rule as a significant recalibration of the balance between confidentiality and limited disclosure, so the practical impact is medium-to-high for institutions that handle supervisory information. The agency also signals continued sensitivity to unauthorized disclosure by retaining the possibility of criminal referral consequences and by tightening the framework around disclosure and FOIA processing.
The Office of the Comptroller of the Currency (OCC) today requested comment on a proposal to implement structural and substantive changes to its rules governing the disclosure of OCC information.
AI Analysis
The OCC issued a notice of proposed rulemaking on August 3, 2026 to restructure and revise 12 CFR part 4, which governs disclosure of OCC information. The proposal matters for compliance teams because it would change when supervised entities may share confidential supervisory information, expand certain disclosure exceptions, and update FOIA processing rules.
Key dates
2026-08-03
OCC issued the notice of proposed rulemaking
2026-10-05 Deadline
Comments on the proposal are due 60 days after publication in the Federal Register
2026-08-05
Federal Register publication date of the proposed rule
Suggested considerations
Compliance teams may wish to review current internal controls for handling OCC nonpublic information and map where the proposed CSI category could affect disclosure workflows.
Firms may wish to assess whether existing information-sharing arrangements with government agencies or service providers would fit within the proposed exceptions and safeguards.
Teams responsible for FOIA or public records requests may wish to update procedures for expedited processing requests and any related appeal handling.
Banks and supervised entities may wish to submit comments on operational burden, safeguards, and the practical impact of the proposed disclosure exceptions before the comment deadline.
What changed
The proposal would make structural and substantive changes to the OCC’s disclosure framework in 12 CFR part 4. According to the OCC, it would create a new nonpublic information category called confidential supervisory information (CSI), modify the prior-approval framework for supervised entities that want to disclose CSI, and add tailored exceptions for business efficiency, government accountability, and supervisory coordination, subject to safeguards.
Compliance impact
The OCC frames the rule as a balance between protecting confidential supervisory information and allowing limited disclosure to support business operations, public confidence, and accountability. For compliance programs, the main impact is operational: firms may need to adjust disclosure approvals, information-sharing controls, and FOIA response processes if the proposal is finalized.
On July 31, 2026, staffs of the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the National Credit Union Administration (collectively, the agencies), issued a statement of enforcement policy in support of U.S…
AI Analysis
On July 31, 2026, the OCC, Federal Reserve, FDIC, and NCUA issued a joint enforcement policy supporting humanitarian relief and financial stability efforts in Venezuela after major earthquakes. The policy matters because it creates a temporary enforcement safe harbor for eligible U.S. financial institutions that provide authorized financial services to persons or entities in Venezuela, reducing BSA-related supervisory risk during the relief period.
Key dates
2026-06-24
Venezuela experienced a pair of strong earthquakes off the northern coast west of Caracas, triggering the humanitarian crisis referenced by the agencies.
2026-07-27
FinCEN issued a substantively similar statement of enforcement policy regarding Venezuela-related financial services.
2026-07-31
The OCC, Federal Reserve, FDIC, and NCUA issued the joint enforcement policy.
2026-07-31
Start of the period during which authorized financial services to persons or entities in Venezuela are covered by the enforcement commitment.
2027-01-29 Deadline
End of the covered period for the joint enforcement commitment.
Suggested considerations
Compliance teams may wish to confirm whether current Venezuela-related activity falls within the scope of authorized financial services covered by the joint statement.
Institutions may wish to verify that their BSA compliance program remains current and that ongoing controls reflect reasonable efforts to comply during the relief period.
Firms may wish to check whether they have had any final FinCEN or OCC enforcement action involving BSA violations in the prior 24 months before relying on the policy.
Sanctions teams may wish to confirm continued compliance with all applicable OFAC-administered sanctions regulations and authorizations.
Institutions with Venezuela exposure may wish to document how they will evidence reliance on the policy and monitor the January 29, 2027 end date.
What changed
The agencies stated that eligible U.S. financial institutions that choose to provide authorized financial services to persons or entities in Venezuela will not be subject to supervisory action, including a citation for a violation of law, or enforcement action related to a Bank Secrecy Act requirement, for those services. The commitment is limited to authorized financial services provided from 2026-07-31 through 2027-01-29 and applies only to statutes or regulations specifically addressed in the joint statement.
Compliance impact
The immediate impact is moderate but targeted: institutions that qualify gain temporary relief from BSA-related supervisory and enforcement action for Venezuela-related authorized services. The agencies still expect compliance with applicable BSA requirements and OFAC sanctions, and the safe harbor is unavailable to institutions with recent final BSA enforcement actions or inadequate ongoing compliance efforts.
The OCC and FDIC are proposing to amend their Community Reinvestment Act (CRA) rules by making certain substantive, technical, and process-oriented changes to refocus on the statutory objective of encouraging banks to meet the credit needs of their communities; to better ensure that community development grants reach…
AI Analysis
The OCC and FDIC issued an interagency notice of proposed rulemaking on July 31, 2026 to revise Community Reinvestment Act rules, with the stated goals of narrowing CRA evaluation toward lending, improving how community development grants are counted, reducing burden on smaller institutions, and clarifying qualification standards. For compliance teams, this is a significant consultation because it signals potential changes to CRA exam scope, bank-size categories, documentation expectations, and strategic plan treatment.
Key dates
2026-07-31
OCC Bulletin 2026-35 issued; interagency proposed CRA rule released
Suggested considerations
Compliance teams may wish to map current CRA inventories against the proposed lending-focused retail services framework to identify deposit-service items that could lose CRA consideration.
Firms may wish to review community development grant and donation controls to determine whether documentation exists to show direct use for a qualifying primary-purpose community development activity.
Large banks may wish to assess whether recipient overhead data, written commitments, attestations, tax filings, and budget records would be available to support the proposed 15% overhead limitation.
Banks near the $1 billion and $10 billion thresholds may wish to model whether the proposed size reclassification would change their CRA evaluation approach, reporting obligations, or supervisory expectations.
Institutions using or considering strategic plans may wish to reassess whether the proposal would make that option more operationally feasible under the revised framework.
CRA and public-disclosure teams may wish to inventory public file and notice processes to determine whether technology-enabled publication changes would require procedural updates.
What changed
['The proposal would narrow the retail banking services analyzed under CRA to focus on credit services and would exclude deposit services from that component of the evaluation, while giving greater weight to activities with a lending nexus.', 'Community development grants would count only if they are directly used for a plan, project, or initiative with community development as a primary purpose; for large banks, defined as banks with assets over $10 billion, the recipient would also need documented overhead costs not exceeding 15% of the grant amount.', 'The bank-size framework would be...
Compliance impact
The OCC describes the proposal as intended to reduce unnecessary burden while preserving continuity in much of the CRA framework, so the immediate impact is consultation-stage rather than binding change. If adopted, the rule could materially change which activities earn CRA credit, how banks are categorized for exams, and the documentation burden for community development grants, especially for banks above $10 billion in assets.
The Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation (the agencies) today proposed targeted changes to their current rules implementing the Community Reinvestment Act (CRA) to better align with the statutory mandate; better ensure that community development grants reach the…
AI Analysis
The OCC and FDIC issued a joint proposed rule on July 31, 2026 to amend the Community Reinvestment Act regulations, with the stated goals of tightening CRA consideration around lending and community development while reducing burden, especially for community banks. The proposal matters because it would rework CRA evaluation mechanics for banks of all sizes and would, if adopted, change what activities count for CRA credit and which banks must meet data collection and reporting requirements.
Key dates
2026-07-31
OCC and FDIC issued the joint proposal amending CRA rules
2026-10-01 Deadline
Approximate comment deadline, calculated as 60 days after the July 31, 2026 publication date if the proposal was published in the Federal Register on the same day as the release
Suggested considerations
Compliance teams may wish to review whether current CRA strategies rely materially on deposit services, since the proposal would exclude deposit services from the retail banking services analysis.
Firms may wish to map all community development grants and donations to identify whether documentation would support that funds are used for the primary purpose of community development and reach the intended assessment areas.
Banks with assets at or below $10 billion may wish to assess the operational impact of being relieved from data collection, maintenance, and reporting requirements under the proposal.
Institutions may wish to compare their current CRA performance-test approach against the proposed lending-focused framework and identify activities that could lose or gain CRA consideration.
Compliance functions may wish to track the Federal Register publication date closely, because the comment window runs for 60 days after publication.
What changed
['The agencies said the proposal would keep the core CRA framework that has generally been in place since 1995, while making substantive, technical, and process-oriented revisions. The proposal follows the agencies’ October 24, 2023 CRA final rules, which were enjoined by the U.S. District Court for the Northern District of Texas before they became effective.', 'The proposal would place greater emphasis on lending performance and would narrow the retail banking services considered under CRA to credit services, expressly excluding deposit services from that part of the analysis.', 'The...
Compliance impact
The OCC describes the proposal as a material recalibration of CRA examinations, especially for banks that rely on deposit-services activity or on current grant-and-donation structures for CRA credit. The agencies frame the changes as reducing burden and improving objectivity, but the proposal could still require significant policy, controls, and documentation updates if adopted.
The Office of the Comptroller of the Currency (OCC) today released a list of Community Reinvestment Act (CRA) performance evaluations that became public during the period of July 1, 2026, through July 30, 2026.
Why this matters
This is an administrative news release announcing the public disclosure of Community Reinvestment Act performance ratings for a specific cohort of national banks and federal savings associations.
The Office of the Comptroller of the Currency today issued a revised compliance guide for the community bank leverage ratio (CBLR) framework as part of its ongoing work to provide regulatory relief for community banks.
Why this matters
This is a news release announcing a revised compliance guide for the Community Bank Leverage Ratio framework that became effective July 1, 2026. The update provides guidance to help community banks understand the revisions and outlines multiple regulatory relief measures (simplified capital requirements, reduced...
The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively, the agencies) are publishing revisions to the Community Bank Compliance Guide for the Community Bank Leverage Ratio (CBLR) framework.
AI Analysis
The OCC, Federal Reserve, and FDIC issued an updated Community Bank Compliance Guide for the Community Bank Leverage Ratio (CBLR) framework to reflect rule changes effective July 1, 2026. For community banks that use the optional CBLR election, the practical significance is a lower qualifying leverage threshold and a more flexible grace-period mechanism for temporary noncompliance.
Key dates
2026-07-01
Revisions to the CBLR framework became effective, including the lower 8% threshold and revised grace-period rules
2026-07-30
OCC Bulletin 2026-34 published the updated Community Bank Compliance Guide
Suggested considerations
Compliance teams may wish to review whether current capital planning and reporting processes reflect the revised 8% CBLR entry threshold.
Firms that use or may elect the CBLR framework may wish to reassess whether they can remain above the 7% grace-period floor during any temporary noncompliance.
Banks may wish to confirm how the four-quarter cure period and the eight-quarter cap over five years would operate in their internal capital contingency planning.
Community banking organizations may wish to reconcile the updated guide with the text of the capital rule, since the guide is only a summary and not binding legal text.
What changed
The agencies revised the non-binding compliance guide to align with the updated CBLR framework in the capital rule. The key substantive change is the minimum leverage ratio for CBLR qualification, which was lowered from greater than 9% to greater than 8%. The grace period for a bank that elects the CBLR framework but temporarily fails to meet the qualifying criteria was revised from two quarters to four quarters, provided the bank maintains a leverage ratio greater than 7% and does not exceed eight quarters in grace-period status over a five-year period.
Compliance impact
The OCC describes this as a regulatory-relief update for qualifying community banks, with the main compliance impact being easier access to the CBLR framework and more time to cure temporary breaches. The consequence of dropping to 7% or below is the need to return to the generally applicable risk-based capital standards.
WASHINGTON - Comptroller of the Currency Jonathan V. Gould today highlighted the OCC's efforts to expand financial literacy, support responsible innovation, and provide consumers with practical educational resources in remarks at the Financial Literacy and Education Commission meeting.
Why this matters
This is a news release documenting remarks by the Comptroller at a Financial Literacy and Education Commission meeting. The content describes ongoing OCC efforts (HelpWithMyBank.gov, resource directories, community bank roundtables) and reiterates the importance of financial literacy in the digital age.
The Office of the Comptroller of the Currency (OCC) issued version 2.0 of the "Allowances for Credit Losses" booklet of the Comptroller's Handbook. The booklet provides information for examiners regarding allowances for credit losses under Accounting Standards Codification Topic 326, "Financial Instruments-Credit…
Why this matters
This is an informational bulletin updating the Comptroller's Handbook to reflect the now-mandatory CECL accounting standard (ASC Topic 326) and interagency policy revisions. It rescinds prior guidance and provides examiners with current supervisory expectations for credit loss allowances.
The Office of the Comptroller of the Currency (OCC), along with the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation (collectively, the agencies), issued a joint statement today on the handling of highly sensitive information during examinations of supervised banks.
Why this matters
This is a policy statement issued jointly by OCC, Federal Reserve, and FDIC addressing examination procedures and data security practices for supervised banks. It establishes binding expectations around identification, minimization, and handling of highly sensitive information, plus a specific 72-hour breach...
Agencies Issue Joint Statement on Handling of Highly Sensitive Information During Bank Examinations The federal bank regulatory agencies today issued a joint statement describing enhanced security procedures for review of highly sensitive information in connection with examinations of supervised banks, such as…
Why this matters
This is a coordinated policy statement from the OCC, Federal Reserve, and FDIC describing enhanced procedures for managing highly sensitive information during bank examinations.
The Office of the Comptroller of the Currency (OCC) today released enforcement actions for July 2026.
Why this matters
This is a standard OCC monthly enforcement actions news release announcing specific enforcement orders (cease and desist against United Texas Bank for BSA/AML deficiencies, prohibition order against individual for theft) and terminations of prior agreements.
Comptroller of the Currency Jonathan V. Gould today issued remarks on his work and progress to ensure the continued relevance of the federal banking system and its ability to meet the evolving financial needs of the American people.
Why this matters
This is a leadership speech marking the Comptroller's one-year tenure. It contains noteworthy policy signals: refocus on material financial risk, support for responsible innovation within federal banking system, deployment of AI/technology in supervision, and reset of supervisory expectations including faster...
On July 13, 2026, following the President's Executive Order on "Restoring Integrity to America's Financial System," the Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), and National Credit Union Administration (NCUA) issued guidance reminding supervised financial…
AI Analysis
The OCC, FDIC, and NCUA issued interagency guidance on July 13, 2026 reminding supervised institutions to apply existing safe-and-sound credit risk management practices when lending to borrowers who are not legally authorized to work in the United States. The guidance does not create a new lending ban, but it signals heightened supervisory focus on underwriting, account management, credit classification, allowance analysis, and consumer compliance for these borrowers.
Key dates
2026-07-13
OCC, FDIC, and NCUA issued the interagency guidance
2026-06-08
CFPB issued its Statement on Ability To Repay and Immigration Status, referenced by the guidance
Suggested considerations
Compliance teams may wish to review underwriting standards to confirm that repayment capacity, source of repayment, and overall financial condition are assessed consistently for borrowers whose work authorization is uncertain.
Firms may wish to test whether account management, credit classification, and allowance methodologies adequately capture elevated credit risk linked to employment authorization uncertainty.
Institutions may wish to review consumer compliance controls for alignment with TILA, Regulation Z, ECOA, and Regulation B when evaluating applicants affected by immigration or work-authorized status.
Risk and compliance teams may wish to update portfolio monitoring, concentration analysis, and documentation standards so that the identified credit risk factors are reflected in governance and reporting.
Community banks may wish to verify that loan policy language and examiner-facing documentation clearly show how these risks are being identified, measured, monitored, and controlled.
What changed
The publication is guidance, not a new rule or statute, and it reinforces existing expectations rather than imposing a new legal prohibition. It states that lending to individuals not legally authorized to work in the United States may present elevated credit risk because their ability to generate income, maintain employment, and remain financially stable may be more uncertain.
Compliance impact
The practical impact is moderate to significant for consumer and retail lending programs because the agencies are signaling that work-authorization uncertainty is a relevant credit-risk factor and a consumer-compliance consideration. The publication could increase supervisory scrutiny of underwriting rationale, documentation quality, and treatment of affected borrowers, especially where institutions cannot show that these risks are consistently incorporated into controls.
The OCC is highlighting the updated Section 314(b) Fact Sheet recently issued by the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN). The updated guidance clarifies how financial institutions can share information with each other about suspected fraud under section 314(b) of the USA…
AI Analysis
The OCC issued Bulletin 2026-30 on 2026-07-09 to highlight FinCEN’s updated Section 314(b) Fact Sheet on voluntary information sharing. The update matters because it broadens and clarifies what participating financial institutions can share to detect suspected fraud and other illicit financial activity, while operating under the Section 314(b) safe harbor.
Compliance teams may wish to review whether current Section 314(b) registration status is current and whether the institution has designated internal points of contact for information-sharing requests.
Firms may wish to assess whether existing BSA/AML and fraud-monitoring procedures explicitly cover the newly highlighted examples of shareable information, including cyber-related data and video surveillance footage.
Institutions may wish to confirm that information-sharing protocols limit disclosures to permissible Section 314(b) purposes and maintain security and confidentiality controls over information received from peers.
Banks may wish to refresh training for BSA, fraud, and investigations staff on when sharing is permissible, including the safe-harbor conditions and the scope of eligible counterparties.
Compliance teams may wish to verify that procedures for responding to requests and documenting reliance on Section 314(b) remain aligned with FinCEN’s updated fact sheet.
What changed
FinCEN’s updated Section 314(b) Fact Sheet clarifies that a participating financial institution may share information about suspected fraud, money laundering, terrorist financing, or other specified unlawful activities with any other financial institution eligible to participate in the Section 314(b) program.
Compliance impact
This is a supervisory guidance update rather than a new binding rule, but it has practical significance because it signals how regulators expect voluntary information sharing to support fraud and BSA/AML controls. The OCC emphasizes the safe harbor for eligible participants, so institutions that do not adapt their procedures may miss an opportunity to improve detection of money laundering, terrorist financing, and fraud.
The Office of the Comptroller of the Currency today issued the "Lending and Loan Portfolio Risk Management" booklet of the Comptroller's Handbook.
Why this matters
The OCC Bulletin 2026-29 announces the issuance of a revised 'Lending and Loan Portfolio Risk Management' booklet that rescissions and combines multiple prior guidance documents.
The Office of the Comptroller of the Currency (OCC) is issuing a notice of proposed rulemaking to implement Bank Secrecy Act (BSA) and sanctions compliance standards applicable to OCC-supervised permitted payment stablecoin issuers (PPSI), as required by the Guiding and Establishing National Innovation for U.S…
AI Analysis
The OCC issued a notice of proposed rulemaking on June 22, 2026 to implement Bank Secrecy Act and sanctions compliance standards for OCC-supervised permitted payment stablecoin issuers under the GENIUS Act. The proposal matters because it would formalize AML/CFT and OFAC compliance expectations, create an OCC enforcement framework, and establish a consultation channel with FinCEN for significant actions.
Key dates
2026-06-22
OCC bulletin announcing the notice of proposed rulemaking was issued
2026-07-22 Deadline
Planned deadline for comments, if the Federal Register publication date aligns with the bulletin date and the OCC’s 30-day comment period is measured from publication
Suggested considerations
Compliance teams may wish to assess whether the entity falls within the OCC-supervised PPSI category or within the state-qualified issuer population covered by OCC authority under the GENIUS Act.
Firms may wish to review existing AML/CFT and sanctions controls against the BSA, FinCEN, and OFAC requirements referenced in the proposal, including reporting, monitoring, and risk assessment procedures.
Compliance teams may wish to map governance, escalation, and record-sharing workflows to the proposed OCC-FinCEN consultation framework, particularly for potential significant supervisory or enforcement matters.
Firms may wish to consider whether their current policies, procedures, and internal controls are sufficiently tailored to stablecoin-specific risks and whether additional board or senior management oversight would be needed.
Compliance teams may wish to evaluate whether they should submit comments during the 30-day Federal Register comment period if aspects of the proposed framework could affect operating models or compliance design.
What changed
The proposed rule would require OCC-supervised PPSIs to comply with the BSA, sections 4(a)(5) and 4(a)(6)(B) of the GENIUS Act, and applicable FinCEN and OFAC regulations, including AML/CFT program, sanctions program, and reporting requirements. It would also create a supervision and enforcement framework for PPSI AML/CFT programs, so the OCC can take AML/CFT supervisory and enforcement action against covered issuers.
The rule would establish a formal consultation process between the OCC and FinCEN when the OCC intends to initiate an AML/CFT enforcement action or a significant AML/CFT...
Compliance impact
The proposal signals a material increase in AML/CFT and sanctions compliance scrutiny for OCC-supervised stablecoin issuers, with explicit supervisory and enforcement consequences for program deficiencies. The OCC describes a framework that could support significant supervisory action or enforcement action, making program design, governance, and escalation controls more consequential for affected issuers.