Office of the Comptroller of the Currency (OCC) Updates its Organizational Structure
The OCC has announced a new organizational framework for bank supervision and updates to the structure of its Office of the Chief National Bank Examiner. As of October 1, 2025, three distinct lines of business replaced the Bank Supervision and Examination group:
- Large and Global Financial Institutions (those with assets over $500 billion and those with a foreign parent), led by Senior Deputy Director Greg Coleman
- Regional and Midsize Financial Institutions (institutions with assets between $30 billion and $500 billion)
- Community Banks (those with assets up to $30 billion)
Acting Senior Deputy Comptrollers for the second and third groups will be selected early next month.
In addition, the Office of the Chief National Bank Examiner will comprise five divisions that will report to Senior Deputy Comptroller and Chief National Bank Examiner Jay Gallagher. The divisions have been streamlined under the following:
- Deputy Comptroller for Supervision Systems and Analytical Support
- Deputy Comptroller for Credit Risk
- Deputy Comptroller for Compliance and Operational Risk
- Chief Economist and Deputy Comptroller for Economics
- Chief Accountant and Deputy Comptroller for Capital, Market Risk and Asset Management
The Office of Financial Technology will report directly to Senior Deputy Comptroller and Chief National Bank Examiner Gallagher.
Treasury Asks for Comment on Potential Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act Rules
The Department of the Treasury published 90 FR 45159, an advance notice of proposed rulemaking (ANPR) to solicit public comment on questions relating to the implementation of the GENIUS Act.
The GENIUS Act tasks Treasury (and various other federal agencies) with issuing regulations that encourage innovation in payment stablecoins while also providing an appropriately tailored regime to protect consumers, mitigate potential illicit finance risks, and address financial stability risks. Through this ANPR, Treasury is seeking public comment on potential regulations that may be promulgated by Treasury, including regarding regulatory clarity, prohibitions on certain issuances and marketing, Bank Secrecy Act (BSA) anti-money laundering (AML) and sanctions obligations, the balance of state-level oversight with federal oversight, comparable foreign regulatory and supervisory regimes, and tax issues, among other things.
Treasury is seeking comment on all aspects of the ANPR from all interested parties and also requests commenters to identify other issues that Treasury should consider.
OCC Reports Second Quarter Mortgage Performance
The OCC has reported on the performance of first-lien mortgages in the federal banking system during the second quarter of 2025.
The OCC Mortgage Metrics Report, Second Quarter 2025 showed that 97.5 percent of mortgages included in the report were current and performing at the end of the quarter, an increase from 97.3 percent one year earlier.
The percentage of seriously delinquent mortgages—mortgages that are 60 or more days past due and all mortgages held by bankrupt borrowers whose payments are 30 or more days past due—decreased from the second quarter of 2024.
Servicers initiated 7,163 new foreclosures in the second quarter of 2025, showing a decrease from the previous quarter and an increase from a year earlier.
National Credit Union Administration (NCUA) Stops Using Reputational Risk
The NCUA has announced it has ceased using reputation risk and equivalent concepts in the examination and supervisory process. These updates follow White House Executive Order 14331, “Guaranteeing Fair Banking for All Americans,” which requires federal banking regulators to remove the use of reputational risk or equivalent concepts that could result in politicized or unlawful debanking.
NCUA employees will no longer base supervisory concerns on reputation risk, nor will they refer to or engage in discussions about reputation risk as part of examinations and supervision contacts of a credit union or credit union service organization.
The agency will continue to include key review areas historically classified under reputation risk, like financial liability associated with active litigation and insider abuse, as part of an examination as necessary. NCUA is currently reviewing and updating regulations, manuals, guidance, and training materials to remove references to reputation risk. While these changes are made, the NCUA issued a Letter to Credit Unions that supersedes any prior direction on reputation risk in other NCUA manuals or guidance.
The NCUA does not expect these changes to materially change a credit union’s examination or examination report. Examination reports and other communications with credit unions will be more streamlined as examiners will focus on addressing material concerns and explaining the credit union’s CAMELS ratings.
Financial Crimes Enforcement Network (FinCEN) Postpones Residential Real Estate Reporting
FinCEN has announced that it will postpone reporting requirements of the Anti-Money Laundering Regulations for Residential Real Estate Transfers Rule
(RRE Rule) until March 1, 2026. FinCEN is taking this step to provide the industry with more time to comply—consistent with the Administration’s agenda to reduce compliance burden—while still adequately protecting the U.S. financial system from money laundering, terrorist financing, and other serious illicit finance threats. The RRE Rule was initially set to become effective on December 1, 2025.
To implement this extension, FinCEN issued a temporary order granting exemptive relief from the reporting requirements. In the interim, any Real Estate Geographic Targeting Orders will remain in effect.
FinCEN also released the Real Estate Report Form to be used for complying with the RRE Rule.
Federal Deposit Insurance Corporation (FDIC) Updates its Consumer Compliance Examination Schedule
The FDIC’s Consumer Compliance Examination Manual has been revised to reflect an updated examination frequency schedule for consumer compliance examinations and Community Reinvestment Act evaluations.
The Third Issue 2025 of Consumer Compliance Outlook is Now Available
This special issue focuses on electronic payments, including the instant payment rails of the FedNow Service and the Real Time Payments network.
- The Electronic Fund Transfer Act, Regulation E, and Instant Payment Services
- Error Resolution Procedures Under the Electronic Fund Transfer Act and Regulation E
- Consumer Liability for Unauthorized Transactions Under the Electronic Fund Transfer Act and Regulation E
- Error Resolution Under Regulation E: Examiner Insights and Common Violations
- Regulatory Calendar
Servicemembers Civil Relief Act (SCRA): Updated Comptroller’s Handbook Booklet
The OCC issued version 1.1 of the “Servicemembers Civil Relief Act” booklet of the Comptroller’s Handbook. The booklet provides information and procedures for examiners in connection with the consumer protections that servicemembers are eligible for under the SCRA.
FinCEN Seeks Comments on 314(a) Reporting Burden
FinCEN has recently published 90 FR 47125, a Notice and Request for Comments on its proposed renewal, without change, of existing information collection requirements found in BSA regulations concerning information sharing between government agencies and financial institutions as required under section 314(a) of the USA PATRIOT Act. Specifically, the regulations require that, upon receiving an information request from FinCEN, a financial institution must search its records to determine whether it maintains or has maintained any account or engaged in any transaction with an individual, entity, or organization named in the request. If a financial institution identifies an account or transaction named in the request, it must report such information to FinCEN in the manner and timeframe specified in the request.
FinCEN is seeking public comment on whether it has accurately estimated the reporting burden of the regulation and whether there are steps it can take to further reduce that burden. It is also seeking answers to a list of 15 questions about Section 314(a) reporting.
OCC Acts to Reduce Community Bank Regulatory Burden
The OCC announced guidance to banks and proposed rulemakings to reduce regulatory burden for community banks, actions built upon the OCC’s continued efforts to tailor its regulatory and supervisory frameworks to minimize burden for its regulated institutions and promote economic growth.
In two bulletins, the OCC clarified examination procedures for community banks. The OCC announced it is removing fixed examination requirements for community banks and instead tailoring the examination scope and frequency to be consistent with risk-based supervision. This approach reduces supervisory burden, maintains the value of the federal charter, and preserves banks’ safety and soundness while ensuring regulatory oversight does not distract banks from serving their communities.
The OCC also announced that it will only use the core assessment standards in the Community Bank Supervision booklet of the Comptroller’s Handbook to examine for retail nondeposit investment products.
In a separate bulletin, the OCC clarified its expectations that community banks should tailor model risk management practices commensurate with the bank’s risk exposures, its business activities, and the complexity and extent of its model use. In particular, the bulletin highlights that the OCC’s model risk management guidance does not impose prescriptive requirements, such as annual model validations. The OCC is also considering additional steps to enhance flexibility and reduce burden related to model risk management. This bulletin is just the first step in refining model risk management guidance for all of the OCC’s regulated institutions.
The OCC also requested comments on two proposed rules. The OCC proposed rescinding its Fair Housing Home Loan Data System regulation, removing largely duplicative data collection requirements for national banks. The proposal would eliminate regulatory burden for banks without having a material impact on the availability of data necessary for the OCC to conduct its fair housing-related supervisory activities. The OCC also proposed broadening eligibility for expedited or reduced licensing procedures to community banks. This proposal would reduce the burden for community banks and tailor requirements to the size and risk profile of an institution.
OCC and FDIC Propose Rule to Focus Supervision on Financial Risks
The FDIC and the OCC jointly issued a notice of proposed rulemaking that would continue their effort to focus supervision on material financial risks. Among other things, the proposal would 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 (MRAs) and other supervisory communications.
By establishing a uniform definition for the term “unsafe or unsound practice” for the purposes of the agencies’ enforcement and supervisory authority under 12 U.S.C. 1818, the proposed rule would promote greater clarity and certainty regarding certain enforcement and supervision standards and ensure bank supervisors prioritize concerns related to material financial risks over those regarding policies, process, documentation, and other nonfinancial risks. The proposed rule would also establish uniform standards for when and how the agencies may communicate MRAs and non-binding supervisory observations as part of the examination process. Finally, the proposal would provide for the tailoring of enforcement actions and MRAs.
Federal Reserve FedPayments Improvement Team Expands Scams and Check Fraud Toolkits
The Federal Reserve FedPayments Improvement team has expanded its online toolkits for educating the banking industry on payments fraud.
The Scams Mitigation Toolkit has three new modules—Scam Prevention and Detection, ScamClassifier™ Model, and Scam Information Sharing.
The Check Fraud Mitigation Toolkit has added a new interactive assessment and more downloadable resources to its three modules on check fraud basics, check fraud schemes, and preventing and detecting check fraud.
Consumer Financial Protection Bureau (CFPB) Issues Advanced Notice of Proposed Rulemaking (ANPR) on Revised Section 1033 Rule
The CFPB has published 90 FR 40986 on the Federal Register, an ANPR seeking comments and data to inform its consideration of four issues related to implementation of section 1033 of the Dodd-Frank Act (Personal Financial Data Rights):
- The proper understanding of who can serve as a “representative” making a request on behalf of the consumer
- The optimal approach to the assessment of fees to defray the costs incurred by a “covered person” in responding to a customer-driven request
- The threat and cost-benefit pictures for data security associated with section 1033 compliance
- The threat picture for data privacy associated with section 1033 compliance
Nacha Approves Rule Changes for International Automated Clearing House (ACH) Transactions
Nacha has announced that its voting members have approved five Nacha Operating Rules changes designed to increase the awareness and efficiency of International ACH Transactions (IATs).
One of the approved Rules refines the definition of an IAT with the goal of making it easier for ACH Originators and Originating Depository Financial Institutions to determine whether a payment should be classified as an IAT. This rule will become effective on September 18, 2026.
The other approved Rules are aimed at transaction and data efficiency. They include:
- Requiring U.S. financial institutions to register IAT-specific contacts in Nacha’s ACH Contact Registry (effective January 1, 2027)
- Adding the optional capability to carry a person’s date of birth for sanctions screening (effective March 19, 2027)
- Recognizing the possibility that the financial agency outside the U.S. is a non-traditional account-holding institution or organization (effective March 19, 2027)
- Adding a new return reason to indicate an issue with sanctions screening as distinct from other return reasons (effective March 17, 2028)
American Bankers Association (ABA) Urges Coordinated Federal Response to End of Penny Production
The ABA Banking Journal reports that the ABA has urged the Federal Reserve and Treasury Department to alleviate the operational challenges caused by the end of penny production, such as by providing public education, giving guidance on rounding transactions, and ensuring the existing penny supply continues to circulate during the transition.
In a letter, ABA said that all stakeholders—banks, retailers and consumers—would benefit from a coordinated federal response to the situation. It asked that the Federal Reserve take immediate action to continue accepting penny deposits at all coin terminals nationwide while more long-term actions are undertaken to manage penny circulation. This deposit infrastructure should be maintained until such time as pennies are formally withdrawn from circulation through a clear and coordinated transition plan, the association said.
Nationwide Multistate Licensing System (NMLS) Updates Process for NMLS Account Administrator Changes
The NMLS Federal Registry news includes a notice that the NMLS has implemented an updated process for requesting Account Administrator changes for both state-licensed companies and federally regulated institutions.
The forms are now available on the NMLS Call Center page on the Resource Center. This update allows companies and institutions to manage their Account Administrators changes directly without having to contact the NMLS Call Center to initiate the request.
FinCEN Issues Frequently Asked Questions (FAQs) to Clarify Suspicious Activity Reporting Requirements
The U.S. Department of the Treasury’s FinCEN issued answers to four FAQs to clarify certain requirements related to suspicious activity reports. By issuing these FAQs, FinCEN is ensuring financial institutions are not needlessly expending resources on efforts that do not provide law enforcement and national security agencies with the critical information they need to detect, combat, and deter criminal activity. FinCEN issued the FAQs jointly with the Board of Governors of the Federal Reserve System, FDIC, the NCUA, and the OCC.
Small Business Lending Data Collection Under the Equal Credit Opportunity Act (Regulation B)
The CFPB proposed revisions to certain provisions of Regulation B, subpart B, implementing changes to the Equal Credit Opportunity Act made by section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The CFPB is reconsidering coverage of certain credit transactions and financial institutions, the small business definition, inclusion of certain data points and how others are collected, and the compliance date. The CFPB believes these proposed changes would streamline the rule, reduce complexity for lenders, and improve data quality, advancing the purposes of section 1071 and complying with recent executive directives.
Agencies Announce Dollar Thresholds for Applicability of Truth in Lending and Consumer Leasing Rules for Consumer Credit and Lease Transactions
The Federal Reserve Board and the CFPB announced the dollar thresholds used to determine whether certain consumer credit and lease transactions in 2026 are subject to certain protections under Regulation Z (Truth in Lending) and Regulation M (Consumer Leasing).
By law, the agencies are required to adjust the thresholds annually based on the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers, known as CPI-W. Transactions at or below the thresholds are subject to the protections of the regulations.
Specifically, based on the 2.1 percent annual percentage increase in the CPI-W as of June 1, 2025, Regulation Z and Regulation M generally will apply to consumer credit transactions and consumer leases of $73,400 or less in 2026. However, private education loans and loans secured by real property, such as mortgages, are subject to Regulation Z regardless of the amount of the loan.
Agencies Announce Dollar Thresholds for Smaller Loan Exemption from Appraisal Requirements for Higher-Priced Mortgage Loans
The CFPB, the Federal Reserve Board, and the OCC announced that the 2026 threshold for higher-priced mortgage loans that are subject to special appraisal requirements will increase from $33,500 to $34,200.
The threshold amount will be effective January 1, 2026, and is based on the 2.1 percent annual percentage increase in the CPI-W, as of June 1, 2025.
The Dodd-Frank Act added special appraisal requirements for higher-priced mortgage loans to the Truth in Lending Act, including that creditors obtain a written appraisal based on a physical visit to the interior of the home before making a higher-priced mortgage loan. The rules implementing these requirements contain an exemption for loans at or below a threshold amount that is adjusted annually to reflect CPI-W increases.
Bank Secrecy Act/Anti-Money Laundering: Discontinuation of Annual Money Laundering Risk System Data Collection
The OCC will no longer annually collect information from community banks through the Money Laundering Risk (MLR) System. Historically, the OCC has utilized the MLR System to understand, analyze, and assess the money laundering (ML) and terrorist financing (TF) risks in the OCC’s community bank portfolio. The OCC has determined that there are alternative, less burdensome means of assessing community banks’ ML/TF risks and, therefore, believes the MLR System is no longer necessary. These actions build upon the OCC’s continued efforts to tailor its regulatory and supervisory frameworks to minimize burden for its regulated institutions and promote economic growth.
