OCC Rewrites Enforcement Playbook to Focus on Big Bank Risks

The Office of the Comptroller of the Currency (OCC) has revised its enforcement playbook to prioritize supervision of significant risks and violations at large banks. In a press release, OCC Comptroller Jonathan V. Gould stated that a focus on check-the-box compliance can distract examiners and bank executives from material financial risks that could endanger a bank's viability.

The OCC's new framework, based on risk-based supervision, will allow it to escalate enforcement actions against large or complex banks based on practices that would not warrant such action against smaller community banks. The revised policies and procedures manuals emphasize material financial risks, enabling the OCC to escalate enforcement actions accordingly.

Additionally, the OCC has proposed amendments to the Violations of Laws and Regulations framework and released a notice of proposed rulemaking for public comment. These changes aim to shift supervisory attention towards material financial risks and substantive violations of law, rather than focusing on policy, process, documentation, and other nonfinancial risks.