The Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC) on August 27, 2026, finalized a rule (which was published in the Federal Register on September 1, 2026) that establishes new standards for determining when a bank has engaged in an “unsafe or unsound practice” and when examiners may issue a Matter Requiring Attention (MRA) (for the FDIC, MRAs will now replace the former MRBAs, Matters Requiring Board Attention).… Continue Reading
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Seventh Circuit Upholds FDIC’s Use of In-House Enforcement Proceedings After “Close and Challenging” Constitutional Analysis
By Scott A. Coleman, Beau Hurtig & Alan S. Kaplinsky on
In a closely watched decision with potentially significant implications for federal banking enforcement, the U.S. Court of Appeals for the Seventh Circuit has upheld the Federal Deposit Insurance Corporation’s authority to adjudicate certain enforcement actions through its own administrative process rather than in federal court. In Bonan v. FDIC, No.… Continue Reading
OCC and FDIC Propose Targeted Amendments to Community Reinvestment Act Regulations: What Banks Need to Know
By Scott A. Coleman, Beau Hurtig & Alan S. Kaplinsky on
Introduction
On July 31, 2026, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) published a joint Notice of Proposed Rulemaking (NPRM) proposing targeted amendments to their Community Reinvestment Act (CRA) regulations. The proposal, issued under Docket ID OCC-2026-0694, RIN 1557-AF57 (OCC) and RIN 3064-AG31 (FDIC), represents a significant pivot in the agencies’ approach to CRA modernization following years of litigation and regulatory uncertainty.… Continue Reading
Federal Reserve Board and FDIC Propose to Modernize Insider Lending Rules by Updating Regulation O Thresholds
The Federal Reserve Board and the Federal Deposit Insurance Corporation have issued substantially identical notices of proposed rulemaking to modernize the regulations governing extensions of credit by banks to their executive officers, directors, principal shareholders, and their related interests. Because the agencies supervise different categories of insured depository institutions, each is proposing amendments to its own regulations, although the proposals are virtually identical in substance.… Continue Reading
CAMELS Reform Arrives: Federal Regulators Propose Sweeping Supervisory Changes
By Scott A. Coleman, Beau Hurtig & Alan S. Kaplinsky on
Posted in Federal Reserve Board, Regulatory and Enforcement
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
OCC, Federal Reserve, and FDIC Finalize Revisions to the Community Bank Leverage Ratio Framework
By Scott A. Coleman & Beau Hurtig on
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
OCC Issues Two Final Rules to Reduce Regulatory Burden on Community Banks (National Banks and Federal Savings Associations and Banks)
By Beau Hurtig & Alan S. Kaplinsky on
Posted in Community Banks, OCC
The Office of the Comptroller of the Currency (OCC) recently adopted two final rules designed to reduce regulatory burden on community banks. The rules expand streamlined licensing procedures for qualifying community banks and rescind an outdated mortgage data collection regulation that applied only to national banks.
According to the OCC, the actions are intended to tailor regulatory requirements to the size and complexity of banking organizations and eliminate duplicative or unnecessary compliance obligations while preserving core supervisory and consumer protection safeguards.… Continue Reading
OCC Proposes to Clarify Activities Permissible for National Trust Banks
By Scott A. Coleman, Beau Hurtig & Alan S. Kaplinsky on
Posted in OCC, Proposed Rulemaking
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
FDIC proposing rescinding merger policy adopted in September
By Beau Hurtig & Scott A. Coleman on
Posted in FDIC
The FDIC has proposed rescinding the agency’s 2024 Statement of Policy on Bank Merger Transactions. FDIC officials said at the time of issuance that the Statement of Policy addresses the scope of transactions that will be reviewed, the process for that review and whether a proposed deal follows the standards established in the Bank Merger Act. … Continue Reading
FDIC, OCC and Justice Department update bank merger guidelines
By Scott A. Coleman & Beau Hurtig on
The FDIC, the OCC and the Justice Department earlier this month issued updated standards for bank mergers. The three agencies acted separately, although officials noted that they had worked with the other agencies involved.
“Continued engagement with our fellow regulators is vitally important, especially as it relates to evaluating the competitive effects of mergers,” FDIC Chairman Martin Gruenberg said.… Continue Reading