On October 6 and 7, 2025, the OCC and the FDIC announced several proposed rules and issued new guidance that will together substantially revise numerous aspects of the supervisory framework for national banks, federal savings associations, and state nonmember banks. Luse Gorman is publishing three Legal Updates with our key takeaways related to each of these developments:

• For our Legal Update on the OCC and FDIC’s proposed rule to establish a uniform definition for the term “unsafe or unsound practice” and revise the process for issuing MRAs, see here.
• For our Legal Update on the OCC and FDIC’s proposed rule to prohibit the agencies from taking adverse action against an institution on the basis of reputation risk, see here.
• For our Legal Update on the OCC’s actions to reduce burdens on community banks, including changes to examination procedures and expanded access to expedited application procedures, see here.

Luse Gorman, PC regularly advises financial institutions on regulatory and compliance developments and enforcement actions from, and licensing applications to, the federal banking agencies. If you have any questions related to these Legal Updates, please contact Brendan Clegg at (202) 274-2034 or bclegg@luselaw.com, or your regular Luse Gorman contact. To learn more about our firm and services, please visit our website.