OCC Renews Guidance Collection on Fair Bank Incentive Compensation Policies
Published Date: 2/17/2026
Notice
Summary
The Office of the Comptroller of the Currency (OCC) is renewing its paperwork collection about fair pay rules for bank workers. This update affects banks and their employees by keeping incentive pay policies clear and fair. Comments on this renewal are open until March 16, 2026, helping shape how these rules work without adding extra costs.
Analyzed Economic Effects
3 provisions identified: 0 benefits, 2 costs, 1 mixed.
Banks must document incentive pay rules
Large national banks and Federal savings associations must have written policies that identify personnel and units involved in incentive pay, describe sources of risk-related inputs and controls, keep documentation so the process can be audited, require board approval and documentation for material exceptions for senior executives, and have the board receive and review an annual (or more frequent) management assessment of the incentive system's design and operation. The guidance says the principles vary with the size and complexity of the banking organization.
Paperwork burden quantified for banks
The OCC estimates annual paperwork burden for this collection as 520 hours for a large bank (480 hours setup; 40 hours yearly maintenance) and 90 hours for a small bank (60 hours setup; 30 hours yearly maintenance). The OCC estimates 1,010 respondents for yearly maintenance (36 large banks; 974 small banks) and a total annual burden of 31,130 hours.
Board approval required for executive pay exceptions
Any material exceptions or adjustments to incentive compensation arrangements established for senior executives must be approved and documented by the organization's board of directors, and the board must receive and review an annual or more frequent assessment by management of the incentive system's effectiveness in aligning risk and safety and soundness.
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