Keeping Up with OCC Changes—What Actually Matters

The OCC - How Can We Explain It?

Don't worry - we'll take you frame by frame it.

As the Office of the Comptroller of the Currency (OCC) prepares to improve

its supervision efforts across all functions, we’ve heard some concerns about

what that means for financial institutions. We've broken down what’s really

changing and one thing that’s not.

The Shifts We’ve Scouted:

1. Midsize, Community, and Large Bank Supervision functions will merge into a single Bank Supervision and Examination unit. While this may sound like a significant reorganization, the practical impact will mostly be felt in the middle and senior management layers. In reality, cross-functional collaboration between these supervision areas has long been a part of how the OCC operates. Large bank examiners have often been deployed to community bank teams for training or specialized reviews, while community and midsize bank examiners frequently participate in rotational assignments across different portfolios.

   
   

2. The Chief National Bank Examiner's office is being reinstated and will now include Bank Supervision Policy and Supervision Risk and Analysis. These groups already work closely together—risk analysts gather raw data from bank supervision, while policy teams use that data to identify trends and shape supervisory approaches. Bringing them under one roof will likely streamline the feedback loop between analysis and policy, ensuring that statistical insights are more directly integrated into decision-making. Risk Analysis is primarily staffed by economists and quantitative analysts, while Bank Supervision Policy draws from a bench of experienced examiners. This pairing could strengthen both data-driven insight and practical application.

   
   

3. The OCC is elevating Information Technology and Security (ITS) to the executive level, appointing a new Senior Deputy Comptroller to lead this critical function. As IT and cybersecurity have become more central to the health and competitiveness of financial institutions, this move reflects their increasing weight in supervisory planning. While we all hope this doesn’t result in another iteration of the CAT (Cybersecurity Assessment Tool), it’s no surprise that tech and data governance remain top priorities. The OCC’s most recent Semiannual Risk Perspective cited rising operational risk and persistent challenges in data governance, particularly within BSA/AML, as areas of prominent concern.

What’s Not Changing:

1. Core supervisory goals, relationships, and expectations remain in place. While the structure is shifting, the day-to-day mission stays the same. Institutions can expect continuity in examiner relationships and a steady focus on governance, compliance, and risk.

In Summary:

This restructuring may streamline decision-making and reinforce focus areas

like cybersecurity and data governance, but it doesn’t signal the complete reinvention of supervision.

RiskScout will continue tracking OCC changes and helping institutions understand what matters most.

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Looking for more regulatory insights? Chat with our expert team, including former OCC regulators, to keep a finger on the pulse of bank compliance. Get in touch here.

Meet the Author:

Ryan McInerny, Director of Product Strategy

Ryan McInerny is the Director of Product Strategy at RiskScout, where he is passionate about creating solutions to enhance the day-to-day lives of financial institution employees. He brings a wealth of regulatory and technical experience to his role as a former National Bank Examiner with the Office of The Comptroller of the Currency (OCC). At the OCC, Ryan was a member of the OCC’s northeast district committees for compliance and commercial credit, where he helped to identify changing industry trends and risk conditions. Ryan brings a strong business sense with his banking expertise, having received his Masters Degree in Business Analytics from UVA's Darden School of Business.