The Office of the Comptroller of the Currency revised its policies for bank enforcement actions and Matters Requiring Attention (MRAs) and proposed a framework for issuing MRAs in response to legal or regulatory violations. The changes focus supervision on material financial risks and substantive violations, require corrective measures to address specific deficiencies, and seek more proportionate and predictable use of enforcement tools. The enforcement policy emphasizes escalation, tailoring and essential corrective action. It allows practices at large or complex banks to trigger enforcement where the same practices at community banks may not, reflecting different supervisory expectations. The MRA policy, published publicly for the first time, limits MRAs to practices, acts or failures that meet the applicable standard and requires them to be tailored using financial risk factors. The proposed rule would divide violations into substantive and technical categories, concentrating supervisory attention on those with the greatest impact on a bank or its customers. Non-substantive violations could be addressed through a mechanism outside the MRA process.
2026-08-27Office of the Comptroller of the Currency
Office of the Comptroller of the Currency revises enforcement and MRA policies, proposes substantive and technical violation categories
The Office of the Comptroller of the Currency revised its enforcement and MRA policies to prioritize material financial risks, substantive violations and tailored corrective action. A proposed rule would classify violations as substantive or technical and provide a mechanism for addressing non-substantive violations outside the MRA process.