OCC:2025-0207: Chief Counsel Office: The American Bankers Association (ABA) appreciates the opportunity to respond to a proposed rulemaking (Proposal) by the OCC to amend its guidelines relating to heightened standards for insured national banks, insured Federal savings associations, and insured Federal branches (Guidelines). Please find attached a copy of ABA's comment letter. ABA endorses the Proposal and appreciates the OCC's recognition that the Guidelines, as currently formulated, establish overly prescriptive standards for banking organizations. We encourage the OCC to consider our recommendation to rescind the Guidelines, or in the alternative, to revise and replace the Guidelines with nonbinding, principles-based supervisory guidance. Thank you again for considering these comments.
OCC Guidelines Establishing Heightened Standards for Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches; Technical Amendments
Activity
American Bankers Association filed 1 comment on this docket between Mar 2, 2026 and Mar 2, 2026. 7 other organizations filed here. The comment window closed 148d ago.
What American Bankers Association filed (1)
Abstract
The Providing Accountability Through Transparency Act of 2023 requires that a notice of proposed rulemaking include the internet address of a summary of not more than 100 words in length of a proposed rule, in plain language, that shall be posted on the internet website www.regulations.gov. The OCC is proposing to amend its Guidelines relating to heightened standards for insured national banks, insured Federal savings associations, and insured Federal branches to increase the average total consolidated assets threshold for applying the Guidelines from $50 billion to $700 billion. In addition, the proposal would clarify certain compliance dates and make other technical amendments. The proposal and the required summary can be found at https://www.regulations.gov by searching for Docket ID OCC–2025–0207 and https://occ.gov/topics/laws-and-regulations/ occ-regulations/proposed-issuances/index-proposed-issuances.html.
View on regulations.gov →Co-filers (7)
See everyone who commented →- American Bankers AssociationTHIS ORG1 filing · confidence 97%
- Axos Bank1 filing · confidence 97%
- Bank Policy Institutetrade assoc.1 filing · confidence 97%
- Community Bankers Association of Illinoistrade assoc.1 filing · confidence 85%
- Consumer Bankers Associationtrade assoc.1 filing · confidence 85%
- Midsize Bank Coalition of Americatrade assoc.1 filing · confidence 85%
- The Woodstock Institutetrade assoc.1 filing · confidence 85%
- U.S. Chamber of Commerce1 filing · confidence 97%