Scott A. Coleman

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The federal banking agencies have proposed on May 19, 2026 the most significant overhaul of the CAMELS supervisory rating system in nearly 30 years, signaling a major philosophical shift in bank supervision under the Trump Administration. The proposal, issued by the Federal Financial Institutions Examination Council (“FFIEC”), would revise the Uniform Financial Institutions Rating System (“UFIRS”) to place greater emphasis on material financial risks and less emphasis on process-oriented supervisory criticisms.… Continue Reading

On April 23, 2026, the Office of the Comptroller of the Currency (OCC), Federal Reserve Board, and Federal Deposit Insurance Corporation (FDIC) jointly issued a final rule revising the Community Bank Leverage Ratio (CBLR) framework. The rule, titled “Regulatory Capital Rule: Revisions to the Community Bank Leverage Ratio Framework,” will take effect on July 1, 2026.It… Continue Reading

The FDIC and the OCC have adopted a joint final rule that will prohibit the agencies from criticizing or taking adverse action against a financial institution based on reputation risk.  The rule is effective June 6.

The rule will also prohibit the agencies from “requiring, instructing, or encouraging an institution to close customer accounts or take other actions on the basis of a person or entity’s political, social, cultural, or religious views or beliefs, constitutionally protected speech, or solely on the basis of politically disfavored but lawful business activities perceived to present reputation risk,” according to a statement from the agencies.… Continue Reading

A bipartisan group of senators, led by Senate Banking, Housing and Urban Affairs ranking Democrat Sen. Elizabeth Warren of Massachusetts, has introduced legislation that would require the FDIC to claw back compensation from failed banks with assets of $10 billion or more.

“The bill would require the Federal Deposit Insurance Corporation (FDIC) to hold executives of large failed banks — like Silicon Valley Bank, which failed three years ago…— financially responsible for some of the costs those failures impose on the rest of the banking system and the economy,” Warren’s office said, in outlining the bill, S.… Continue Reading

In a move viewed favorably by FDIC-regulated institutions, the FDIC has approved amendments to the agency’s Guidelines for Appeals of Material Supervisory Determinations that were proposed back in July of 2025. A new supervisory appeals office will now establish review panels that include someone with bank supervisory experience and someone with industry experience.… Continue Reading

On January 12, 2026, the Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking to amend its national bank chartering regulation, 12 C.F.R. § 5.20, to clarify a point the agency views as well settled: national banks chartered as trust companies may engage in certain non-fiduciary activities in addition to fiduciary activities.… Continue Reading

The NCUA has issued a Notice of Proposed Rulemaking to codify the elimination of reputational risk from its supervisory program, becoming the latest federal financial regulator to do so.

“NCUA has determined that assessing reputation risk is subjective, ambiguous, and lacking in measurable criteria,” the agency said, in announcing the action.… Continue Reading

The FDIC and the OCC have issued a Notice of Proposed Rulemaking that seeks to establish a standard definition for what constitutes an “unsafe or unsound practice.”

“Too often, examiners focus on a litany of process-related items that are unrelated to a bank’s current or future financial condition,” Acting FDIC Chairman Travis Hill said, in a statement outlining the NPRM, which was unanimously adopted by the agency board. … Continue Reading

The FDIC and the OCC have approved the joint publication of a Notice of Proposed Rulemaking that would codify the removal of reputational risk from their supervisory programs.

“Examining for reputation risk can result in agency examiners implicitly or explicitly encouraging institutions to restrict access to banking services on the basis of examiners’ personal views of a group’s or individual’s political, social, cultural, or religious views or beliefs, constitutionally protected speech, or politically disfavored but lawful business activities,” the FDIC staff said, in a memo.… Continue Reading

Republican senators on the Banking, Housing and Urban Affairs Committee are asking banking regulators to review their process of using Matters Requiring Attention (MRA) in the bank supervisory process.

“If used effectively, these are valuable supervisory tools that can mitigate broader issues and maintain financial stability,” 11 GOP senators said in a letter to the FDIC, OCC and the Federal Reserve.… Continue Reading