OCC's Gould limiting examiner time at banks

Jonathan Gould
Comptroller of the Currency Jonathan Gould
Bloomberg News
  • Key insight: Comptroller of the Currency Jonathan Gould said Monday that the OCC has imposed quantitative limits on how many days examiners can spend at banks, dovetailing with recent efforts to narrow the issues they pursue during examinations.
  • Expert quote: "This is not about undermining the strength of bank supervision, but making sure we're focused [on] not diluting supervision and making sure we're not burdening you with wild goose chases or criticisms about your board minutes and failing to dot an 'i' or cross a 't.'" — Comptroller of the Currency Jonathan Gould 
  • Forward look: The agency chief did not specify the number of workdays covered by the new limits or how they vary by bank or examination team.

The Comptroller of the Currency Jonathan Gould Monday said the agency has limited the number of days its examiners can spend on-site at banks, part of a broader effort to narrow the scope of bank supervision and focus examiners on "material financial risks."

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In his remarks, delivered to a crowd at the Association of Military Banks of America's Military Banking Summit 2026, Gould framed the move as a departure from previous administrations, in which he argues bank examination was an exhaustive box-checking exercise.

"[We've put] actual workday limits on how many days our examiners can spend wandering around your banks and poking into this corner or that corner," Gould said. "This is not about undermining the strength of bank supervision, but making sure we're focused [on] not diluting supervision, and making sure we're not burdening you with wild goose chases or criticisms about your board minutes and failing to dot an 'i' or cross a 't.'"

The changes come as banking agencies during the Trump administration have moved to "reset the risk tolerance" for the banking system and strengthen supervision, he said. Gould did not specify the number of workdays covered by the new limits or how they may vary by bank or examination team. A request for additional information was not immediately answered by the OCC Monday. 

The limits on time spent at supervised banks is consistent with recent efforts by the administration to rein in the qualitative aspects of supervision. The OCC and Federal Deposit Insurance Corp. recently finalized a rule defining "unsafe or unsound" practices, which Gould said would put supervision on a firmer legal foundation and help establish clearer boundaries for examiners. 

The joint final rule — building on a proposal from last fall — directs supervisors to focus only on "material financial risks," raises the bar for when supervisors can flag matters requiring attention, or MRAs, and creates a new process for examiners to flag less consequential concerns without requiring corrective action. The OCC also issued a revised examination guidance document alongside the joint rule. The final rule marks the first time regulators have defined "unsafe or unsound practices" in an official regulation. 

Under the new standard, an unsafe or unsound practice would be one "contrary to generally accepted standards of prudent operation" that, if continued, is likely to materially harm a bank's financial condition or that of the FDIC's Deposit Insurance Fund used to rescue failed banks' depositors. The rule also states that financial harm includes negative impacts to capital, asset quality, earnings, liquidity or sensitivity to market risk. As part of the new practices, the OCC also directed examiners to weigh the cost of a review against its benefits and generally limits look-backs involving failures to detect or report suspicious activity to one year or less. 

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The move to narrow bank supervisors' ability to flag unsafe or unsound practices does give banks more discretion over how they manage supervisory risks — but with that flexibility comes greater responsibility for addressing small problems before they become material.


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