OCC Proposes Fixes for Bank Violation Supervision Framework
Published Date: 9/1/2026
Proposed Rule
Summary
The Office of the Comptroller of the Currency (OCC) proposes to revise the supervisory framework for the issuance of matters requiring attention (MRAs) in response to violations of laws or regulations and for addressing violations for which the OCC does not take an enforcement action or issue an MRA.
Analyzed Economic Effects
4 provisions identified: 3 benefits, 0 costs, 1 mixed.
MRAs Limited to Substantive Violations
The OCC would limit issuance of Matters Requiring Attention (MRAs) to violations it defines as "substantive violations." The OCC says this change would affect all 986 OCC-supervised institutions (about 602 are small entities) and expects it would cite fewer violations as substantive, meaning institutions would have fewer MRAs to remediate and could save on remediation costs such as external consultants (examples cited: $150 to $1,200 per hour); the OCC expects aggregate annual direct cost savings would be de minimis.
New 'Technical Violations' Supervisory Track
The OCC would create a new category called "technical violations" for violations that could not meaningfully impact the institution or its customers. For technical violations the OCC may direct an institution to correct the issue but would not prescribe how to correct it, would generally document the finding but would not track whether the institution corrected it, and the institution would not be required to notify the OCC when it has corrected the violation.
Excludes Safety and Soundness Guidelines From MRA Tests
The OCC would explicitly exclude noncompliance with guidelines contained in the OCC's Safety and Soundness Standards (12 CFR part 30) from the definitions of substantive and technical violations. Such noncompliance would instead be addressed through existing supervisory mechanisms and would not, by itself, support issuance of an MRA unless it later met the OCC's MRA criteria.
Tailoring MRA Use by Size and Risk
The OCC would tailor whether and how it issues MRAs based on an institution's capital structure, complexity, activities, asset size, and other risk factors. For example, a higher number of violations would generally be required to establish a pattern at a large institution than at a small institution, while the error-rate threshold to establish a pattern would be lower at a large institution than at a small institution.
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