OCC Revamps Enforcement Playbook to Target Big-Bank Risks

The Office of the Comptroller of the Currency oversees national banks, federal savings associations and US branches of foreign banks. Its overhaul advances a broader return to risk-based supervision, directing examiners toward deficiencies that could materially damage capital, asset quality, earnings or liquidity. The shift is intended to move supervisory resources away from process, documentation and other nonfinancial concerns while preserving tougher expectations for large or complex institutions.

On Aug. 27, 2026, the OCC issued revised manuals PPM 5310-3 and PPM 5400-11, publishing the latter’s Matters Requiring Attention framework for the first time. The changes, aligned with a final rule issued jointly with the Federal Deposit Insurance Corporation, organize enforcement around escalation, tailoring and focused corrective action. The OCC may escalate a case involving a large or complex bank even when the same conduct would not prompt enforcement against a community bank, reflecting differences in size, activities, capital structure and complexity.