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pc nid 94869 Aug 28, 2026 pdonofrio@vixio.com US Track 2 Newsroom - Office of the Comptroller of the Currency (OCC) financial services
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Office of the Comptroller of the Currency Proposes Rule Distinguishing Substantive and Technical Violations

On August 27, 2026, the Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking to refine the standard for issuing matters requiring attention (MRA) in response to violations of laws and regulations under 12 CFR 4.92. The proposed rule establishes two distinct categories of violations: "substantive violations" and "technical violations," designed to focus supervisory attention on violations that could meaningfully impact banks or their customers. Under the proposal, the OCC would limit MRA issuance to substantive violations only—those whose nature, duration, frequency, or severity could meaningfully impact a bank or its customers. The OCC would deem a violation substantive if it meets at least one of five criteria: constitutes a systemic issue or pattern; has had or reasonably could have a direct, clear, predictable, and more than minimal impact on the bank's financial condition; has had or reasonably could have a more than minimal impact on the accuracy of the bank's books and records; requires more than minimal restitution or reasonably could have a more than minimal adverse impact to customers; or involves insider misconduct or self-dealing. Technical violations—those for which the OCC does not take enforcement action or issue an MRA—would be handled separately. Examiners could direct banks to correct technical violations but could not prescribe how correction must occur or require remediation steps unrelated to the violation itself. The proposed rule applies to all OCC-supervised institutions, including national banks, federal savings associations, and federal branches and agencies. The comment period closes 30 days after publication in the Federal Register. Interested parties should submit comments during this window. Further information is available from the OCC's Chief Counsel's Office at (202) 649-5490.

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US Office of the Comptroller of the Currency Proposes Rule Distinguishing Substantive and Technical Violations

On August 27, 2026, the US Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking (NPRM) to refine the standard for issuing Matters Requiring Attention (MRA) in response to violations of laws and regulations under 12 Code of Federal Regulations (CFR) 4.92 . The proposed rule establishes two distinct categories of violations: "substantive violations" and "technical violations" designed to focus supervisory attention on violations that could meaningfully impact banks or their customers. Under the proposal, the OCC would limit MRA issuance to substantive violations only (i.e., those whose nature, duration, frequency or severity could meaningfully impact a bank or its customers). The OCC would deem a violation substantive if it meets at least one of five criteria: Constitutes a systemic issue or pattern. Has had or reasonably could have a direct, clear, predictable and more than minimal impact on the bank's financial condition. Has had or reasonably could have a more than minimal impact on the accuracy of the bank's books and records. Requires more than minimal restitution or reasonably could have a more than minimal adverse impact to customers. Involves insider misconduct or self-dealing. Technical violations (i.e., those for which the OCC does not take enforcement action or issue an MRA) would be handled separately. Examiners could direct banks to correct technical violations but could not prescribe how correction must occur or require remediation steps unrelated to the violation itself. Interested parties may submit comments on the proposed rule at this link up until 30 days after its publication in the Federal Register.