OCC Shake-Up: What Banks Should Watch

The OCC offered buyouts drawing nearly 800 employees, raising pressing questions about how this shake-up will affect banks. From examiner standards under review to MRAs potentially becoming law, here are the key regulatory shifts banks need to watch.

Regulatory Insights Newsletter | October Edition 2025

The Big Picture

At the end of September, the Office of the Comptroller of the Currency (OCC) offered buyouts that drew nearly 800 employees. This significant workforce reduction has raised pressing questions about how the shake-up will affect banks going forward. Conversations with industry colleagues reveal one consistent theme: uncertainty.

Key Takeaways

Examiner Standards Under Review

The OCC is re-evaluating how it measures compliance. Expect faster, more binary judgments on whether a bank is compliant — with less room for discussion or remediation.

MRAs / MROs May Become Law

“Matters Requiring Attention” (MRAs) and “Matters Requiring Ongoing Attention” (MROs) could shift from supervisory guidance into statutory requirements, raising the stakes for banks.

Loss of Institutional Knowledge

With many senior examiners departing, banks are increasingly facing junior examiners who are still learning on the job. This often creates additional questions, delays, and unnecessary back-and-forth, resulting in a more fragmented, less predictable exam process.

Merger Review Volatility

The OCC recently reinstated expedited merger review after scrapping it in 2024. This back-and-forth underscores the unpredictability of regulatory direction.

Congressional Pressure

Lawmakers are pressing regulators to overhaul MRAs for consistency and transparency. This could limit examiner discretion but also increase compliance burdens.

Compliance Risk Remains #1

The OCC’s own reports continue to flag BSA/AML and consumer compliance as top risks. With fewer buffers, scrutiny in these areas will only intensify.

What This Means for Banks

Expect less flexibility — junior examiners may escalate issues quickly and inconsistently.
Prepare for inefficiency — build in time for added back-and-forth during exams.
Treat MRAs/MROs as binding — prepare as if they’re statutory obligations.
Strengthen governance — document controls and institutional knowledge before gaps emerge.
Watch merger policy shifts — opportunities may exist, but volatility is high.
Engage proactively — shape upcoming rules through associations and comments.

Emerging AI, Data, and Model Oversight

With evolving technology and data usage in financial institutions, examiners are beginning to probe:

AI model risk governance
Third-party oversight of technology providers
Data governance frameworks
Data quality and lineage

But because standards are still emerging and examiner experience is variable:

Interpretations may be inconsistent or overly strict
Banks must prepare for more technology enabled evidence and documentation

Bottom Line

With fewer senior examiners, banks face a double challenge: advancements towards more automated oversight and less experienced exam teams. Those that treat today’s uncertainty as a catalyst — by investing in governance, control frameworks, and certification of critical assets will be best positioned to navigate both the stricter oversight and the inconsistencies likely to follow.

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