On October 1, the office of the Comptroller of the Currency (OCC) will implement a major reorganization of its bank supervision framework. This change significantly alters how institutions are grouped and examined as Community Banks.
The New Supervisory Framework
Under the reorganization, the OCC will realign institutions into three supervisory categories:
- Large & Global – institutions with $500B+ in assets and foreign-owned banks
- Regional & Midsize – institutions with $30B–$500B in assets
- Community Banks – institutions up to $30B in assets
What This Means for Community Banks
1. Expanded Peer Group
Institutions in the $10–30B range will now be included in the Community Bank line. Smaller Community Banks will now be benchmarked against a larger and more complex peer group, even if exam scope is tailored to their size and risk profile.
2. Broader Examiner Expertise
With $10–30B institutions now included in the Community Bank portfolio, examiners will need to draw on supervisory tools more common in the midsize line such as stress testing, advanced liquidity oversight, and vendor/fintech risk analysis particularly for larger Community Banks.
3. Tailored Exam Scoping
According to Comptroller Gould, the OCC’s new approach will tailor the exam scope to each bank’s size, complexity, and risk profile. Smaller Community Banks may see lighter exam scoping, but larger Community Banks should expect broader, more robust modules.
4. Higher Enforcement Visibility
With larger and more complex banks now included, enforcement actions and civil monetary penalties will feature more prominently across the Community Bank portfolio.
Why It Matters Now
This shift redefines the playing field. For Community Banks, it means new peer comparisons, evolving supervisory expectations, and greater focus on enforcement trends.
At iKinetiq, we have supported institutions across all supervisory categories from Community Banks to midsize institutions to systemically important banks. We know how examiner expectations shift across portfolios, and we bring that insight to help Community Banks prepare under this new supervision framework.
Next Steps
Now is the time to get ahead of the change. Our Regulatory Risk Profile provides a data-driven view of enforcement trends, peer benchmarks, and risk distribution for Community Banks under the OCC’s new supervisory structure.
📅 Schedule your complimentary consultation with our team to review your bank’s risk profile in this new environment.
👉 Official OCC announcement: OCC News Release
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