Davis Polk partner Dan Stipano discussed with S&P Global Market Intelligence the OCC’s recent updates to its enforcement manual, which would allow the agency to more quickly address noncompliant banks that are not promptly fixing their “persistent weaknesses.”

“Going forward, the OCC could take more serious public actions faster than they did before, so banks should act fast if any issues are brought to their attention,” Dan explained. “Banks should pay attention to supervisory criticism at the earliest possible stage.”

Dan also added, “You don’t want a small, unmanageable problem to turn into a large, unmanageable one. Because the OCC is saying, ‘If it turns into a large, unmanageable one, we’re going to take serious action against you.’”

“OCC intensifying crackdown on noncompliant banks in wake of failures,” S&P Global Market Intelligence (June 7, 2023) (subscription required)

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