Daily Compliance Brief — OCC and FDIC Narrow Standards for Matters Requiring Attention

August 27, 2026

Signal

The Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC) issued a joint final rule on August 27, 2026, defining standards for unsafe or unsound practices and Matters Requiring Attention (MRAs). The rule was published through OCC Bulletin 2026-40 and establishes a more defined materiality threshold for supervisory action.

Under the framework, MRAs must generally involve practices that could materially harm a bank's financial condition, create material risk to the Deposit Insurance Fund, or constitute an actual banking-law violation. The agencies also introduced a separate category for informal supervisory observations covering weaknesses that do not meet the MRA threshold.

The rule changes how supervisory findings may be categorized and requires greater distinction between material financial risks, regulatory violations, and lower-level control weaknesses.

Why it matters

Banks should reassess how compliance and risk issues are classified, escalated, and documented within supervisory response frameworks.

Control owners should maintain clear evidence linking identified weaknesses to applicable regulatory requirements and material risk, particularly where issues may fall outside the revised MRA threshold.

Management reporting should distinguish formal remediation requirements from supervisory observations without treating lower-level findings as exempt from applicable legal obligations.