OCC proposes new MRA framework based on violation type

The Office of the Comptroller of the Currency issued a notice of proposed rulemaking (Docket ID OCC-2026-0529, RIN 1557-AF56) to revise the supervisory framework for matters requiring attention (MRAs) arising from violations of laws or regulations.

The proposal creates two categories - "substantive violations" and "technical violations." An MRA could be issued only for a substantive violation; technical violations would be addressed through an alternative mechanism. A substantive violation is defined as one whose nature, duration, frequency, or severity could meaningfully impact the institution or its customers, with five specific categories enumerated in the notice.

The rule would replace the term "actual violation" with "substantive violation" in 12 CFR 4.92(c) and invites comment on whether to remove the phrase "banking or banking-related" from that standard. The OCC seeks input on the overall framework and the proposed terminology.

Comments must be received by Oct. 1, 2026 via the Federal eRulemaking Portal (Regulations.gov) using Docket ID OCC-2026-0529, or by mail to the Chief Counsel's Office, 400 7th Street SW, Suite 1E-216, Washington, DC 20219. Contact persons listed are Eden Gray, Assistant Director; Marjorie Dieter, Special Counsel; Anna Mills, Counsel; and Harry Naftalowitz, Attorney, phone 202-649-5490.

The agency states the change is intended to focus examiner and institution attention on violations most likely to affect prudent operation while preserving the ability to require corrective action where needed.