Compliance Journal November 2025
Special Focus Recap of Recent Discussion with Supervisory Agencies at WBA Compliance Forum At the November WBA Compliance Forum, attendees participated in a discussion with representatives of the Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (FRB), and the Federal Deposit Insurance Corporation (FDIC) (collectively, the Supervisory Agencies). In a panel format the Supervisory Agencies answered questions submitted by attendees which ranged in topics from technical compliance requirements to expectations of recently reduced examination schedules. The following is a summary of the discussion and recommendations by the Supervisory Agencies. As with all compliance-related matters, specific facts of each situation are important. Answers to the compliance questions discussed with the Supervisory Agencies could be different with new or differing facts. Overall Statements by the Supervisory Agencies The discussion opened with remarks from each representative of the Supervisory Agencies of important information related to recent releases and regulatory findings. The OCC outlined several actions taken to reduce regulatory burden for community banks, including: (1) updates to OCC policies to eliminate mandatory examination activities not required by statute or regulation; (2) a shift in the review of retail nondeposit investment products, which will no longer rely on OCC’s “Retail Nondeposit Investment Products” booklet, but instead on the bank’s compliance with applicable laws and regulations; and (3) a reminder that community banks should tailor model risk management practices to their own risk exposures, business activities, and model complexity. The OCC also mentioned proposals meant to: (1) eliminate its Fair Housing Loan Data System regulation citing that the information is largely duplicative in nature to the data collected and reported under the Home Mortgage Disclosure Act (HMDA) and other fair lending regulations; and (2) broaden eligibility for quicker and more streamlined licensing decisions for community banks. Each of these initiatives define “community banks” as an institution with up to $30 billion in assets. Lastly, OCC reminded attendees of a recent update to its Equal Housing Lending poster template which added a new statement to the Spanish version of the template. Links to the releases referenced by OCC are found at the end of this article. The FRB recommended attendees review 2013–19 Consumer Affairs Letter, updated in June 2025 to clarify that reputational risk will not be a component of examination programs in FRB-supervised banks, as the primer of FRB’s Community Bank Risk-Focused Consumer Compliance Supervision Program. The program remains the focus of FRB compliance examinations for community banks. Consistent with the risk-focused compliance program, FRB mentioned that examiners would likely look to review what training had been completed by bank staff in the areas of fair lending, Community Reinvestment Act (CRA), and for unfair, deceptive, or abusive acts or practices (UDAAP). FRB also recommended that banks: (1) monitor policy exceptions and to better understand the reason for and frequency of exceptions; (2) monitor customer complaints and ensure bank staff understand what constitutes a complaint and how to escalate the compliant to find resolution; and (3) understand their CRA efforts and have documentation to help explain the bank’s community development activities.