meta_id 3440027

On August 27, 2026, the Office of the Comptroller of the Currency (OCC) released two revised Policies and Procedures Manuals (PPM) governing bank enforcement actions and supervisory matters. Revised PPM 5310-3 addresses bank enforcement actions and related matters, replacing the previous version issued on May 25, 2023. Revised PPM 5400-11 governs matters requiring attention (MRA), replacing the version issued on February 27, 2026. The OCC had not previously published PPM 5400-11 publicly. The revisions align with a joint final rule issued by the OCC and Federal Deposit Insurance Corporation (FDIC) on August 27, 2026, which defines "unsafe or unsound practice" under section 8 of the Federal Deposit Insurance Act and revises the supervisory framework for MRA issuance. The OCC prioritises material financial risks over nonfinancial concerns such as policy, process, and documentation issues. The agency will generally not take enforcement action without first providing banks an opportunity to remediate deficiencies through the supervisory process. The Revised Enforcement Action PPM establishes three guiding principles: escalation, providing banks opportunities to remediate before enforcement action; tailoring, adjusting enforcement responses based on financial risk factors including capital structure, complexity, activities, and asset size; and focus, issuing targeted enforcement actions with corrective actions addressing specific deficiencies. The revised manual establishes that enforcement actions terminate when banks achieve "substantial compliance," satisfying essential requirements even if minor, isolated requirements remain unsatisfied. The Revised MRA PPM establishes uniform standards for MRA issuance, permitting MRAs only for practices that are contrary to prudent operation standards and could materially harm the bank's financial condition or present material risk to the Deposit Insurance Fund, or constitute actual violations of banking law. The manual introduces "supervisory observations" for weaknesses not meeting MRA standards and "other violations" for which no enforcement action or MRA is issued. The OCC rescinded OCC Bulletin 2023-16 with this release. These policies apply to all OCC-supervised institutions, including national banks, federal savings associations, and federal branches and agencies.