Bank Rules Loosen Up: OCC Jumps Threshold to $700 Billion
Published Date: 12/30/2025
Proposed Rule
Summary
The OCC is updating its rules for really big banks and savings groups by raising the size limit from $50 billion to $700 billion before extra rules kick in. This means fewer banks will face these tougher standards, and the update also clears up some deadlines and fixes small details. If you’re involved, get ready to share your thoughts by March 2, 2026!
Analyzed Economic Effects
5 provisions identified: 4 benefits, 0 costs, 1 mixed.
Guidelines threshold raised to $700B
The OCC proposes raising the asset threshold that triggers its "heightened standards" from $50 billion to $700 billion. That change would shrink the number of banks covered by the Guidelines from 38 institutions to 8 institutions based on the most recent data.
Smaller big banks can tailor risk rules
Banks with average total consolidated assets under $700 billion (Excluded Institutions) would generally be outside the Guidelines and could design risk governance frameworks tailored to their own size and operations. The OCC says these Excluded Institutions could use freed-up resources to invest in product and service development, IT upgrades, and customer service improvements.
Recordkeeping burden and OMB submission
The proposal updates the Paperwork Reduction Act submission (OMB Control No. 1557-0321) and revises the number of respondents required to comply with the Guidelines' recordkeeping requirements to 8 respondents. The notice lists estimated burden as 3,776 hours per respondent and 30,208 hours total for the collection.
OCC keeps authority for special cases
Even if a bank has less than $700 billion in assets, the OCC would keep the authority to apply the Guidelines if the bank's parent controls a covered bank or if the OCC determines the bank's operations are highly complex or present heightened risk.
Small entities not significantly affected
The OCC certified under the Regulatory Flexibility Act that the proposed change would not have a significant economic impact on a substantial number of small entities (SBA small-entity definition: banks or savings institutions with total assets of $850 million or less). Because of this, the OCC did not prepare an initial Regulatory Flexibility Analysis.
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