OCC Issues Bulletins to Reduce Regulatory Burden for Community Banks

On October 6, 2025, the Office of the Comptroller of Currency (OCC) issued several bulletins collectively designed to provide regulatory relief to community banks. Included are three bulletins modifying examination guidance and two bulletins announcing notices of proposed rulemaking, all targeted at community banks, which were previously clarified as banks with assets up to $30 billion. The OCC stated that it will eliminate fixed examination requirements and instead tailor scope and frequency based on risk, while limiting reviews of retail nondeposit investment products to core assessment standards. Further, the OCC clarified that model risk management practices should be proportionate to each bank’s risk profile and complexity, with no prescriptive requirements such as annual validations, and signaled further steps to enhance flexibility. Finally, the OCC issued two proposed rulemaking. One rulemaking would rescind its Fair Housing Home Loan Data System regulation, which would remove duplicative data collection requirements. The other rulemaking would expand expedited licensing eligibility for community banks.

Below, we provide an overview of these OCC bulletins.

Bulletin name	Bulletin summary
Bulletin 2025-24: Frequency and Scope for Community Banks	Effective January 1, 2026, the OCC will eliminate all requirements for examination activities set by OCC policy. Instead, examiners will conduct risk-based examinations in alignment with statute and regulation with a heightened focus on material financial risks. The agency emphasized the use of off-site analyses, quarterly monitoring and bank-provided reports, as tools for examiners in identifying pertinent risks. Examiners will leverage a community bank’s audit, risk management, reporting and other functions in their assessment when these functions have been deemed reliable. The agency is reassessing its data-collection methods for community banks to explore potential for less burdensome options.
Bulletin 2025-25: Retail Nondeposit Investment Products: Exam Procedures for Community Banks	OCC examiners will no longer use the detailed procedures of the Retail Nondeposit Investment Products (RNDIP) booklet in their review of RNDIP activities at community banks. Instead, examiners will use only the core assessment standards outlined in the “Community Bank Supervision” booklet. Community banks are still subject to complementary laws and regulations related to their RNDIP offerings including: the Gramm–Leach–Bliley Act, federal securities laws, federal and state insurance laws, consumer privacy laws, Bank Secrecy Act/anti-money laundering laws, and prudential OCC regulations.
Bulletin 2025-26: Model Risk Management: Clarification for Community Banks	The OCC clarified that community banks have flexibility to tailor their model risk management practices to their specific risk exposures, business activities, and model complexity. While model validation guidance does not impose annual model validation requirements for community banks, practical application of the guidance should be used in relation to the bank’s risk exposures, business activities, and the complexity and extent of its model use. Banks will not receive negative supervisory feedback solely for choosing a validation frequency or scope that is reasonable for their circumstances.
Bulletin 2025-27: Rescission of 12 CFR 27, ‘Fair Housing Home Loan Data System’: Notice of Proposed Rulemaking	A notice of proposed rulemaking (NPR) was issued to rescind 12 CFR 27, the “Fair Housing Home Loan Data System” (Part 27). Part 27 established quarterly recordkeeping requirements for Home Mortgage Disclosure Act filers and non-filers that met certain thresholds and a data collection system for monitoring national banks and any of their subsidiaries for compliance with the Fair Housing Act and the Equal Credit Opportunity Act. The OCC considers the regulation obsolete due to its duplicity and the inconsistency of requirements across other legal authorities. The agency notes its recission would reduce regulatory burden without affecting the agency’s ability to conduct fair housing-related oversight. Public comments are requested for 60 days after publication in the Federal Register.
Bulletin 2025-28: Community Bank Licensing Amendments: Notice of Proposed Rulemaking	The OCC proposed amendments to simplify licensing requirements for corporate activities and transactions involving national banks and federal savings associations with less than $30 billion in assets. Under the proposal, “well-capitalized community banks would be granted expedited or reduced filing procedures under 12 CFR 5. The proposal aims to create a pathway to increased corporate activities and transactions for community banks by tailoring requirements to banks’ size and risk profiles. Public comments are requested for 60 days after publication in the Federal Register.

How Forvis Mazars Can Help

In the heavily regulated banking industry, leaders face more challenges than ever, from striving to meet shareholder and regulatory expectations to pursuing digital innovation. The OCC is prioritizing a risk-based framework for community banks, with a strong focus on enhancing internal monitoring and control systems. Forvis Mazars can help your financial institution tackle issues inherent to the industry, including market growth, internal control threats, industry consolidation, and compliance. We have the skills and experience in financial services that you can trust, combining a focus on Unmatched Client Experience^® with the resources of a global firm. Serving you is our passion and privilege.

If you have any questions or need assistance, please reach out to a professional at Forvis Mazars and let us be a resource for your institution.

Related FORsights