On September 10, the Comptroller of the Currency, Jonathan V. Gould, released his remarks to the U.S. Financial Stability Oversight Council to review the post-2008 chartering, regulatory and supervisory framework for the federal banking system. Gould focused on resetting risk tolerance for the federal banking system, acknowledging how the regulatory approach following the 2008 financial crisis “sought to micromanage bank balance sheets and activities.” The OCC recognized that risk elimination strategies had often been pursued instead of risk management, prompting a shift in regulatory philosophy.

With respect to chartering, Gould stated that the OCC “will no longer have a de facto ‘no’ policy.” On regulation, Gould indicated that the OCC would prioritize capital and liquidity reforms with other banking agencies. Specifically, among other things, Gould stated that: (i) the regulatory framework for national banks would be addressed, including “recovery planning and heightened standards”; (ii) consideration will be given to altering the “leverage ratio framework” and raising applicable regulatory asset thresholds for community banks; and (iii) the OCC would work with other banking agencies “to eliminate the use of reputation risk and define key supervisory concepts, like unsafe and unsound practices.” Finally, with respect to supervision, Gould advised that the OCC started the process of “reviewing supervisory strategies” for the purposes of “eliminating ongoing or targeted examination activities that are not related to material financial risks.”