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OCC explains filing decision process


June 18, 2026 / By ICBA

The OCC clarified the standards for its decisions on filings.

Details: In a bulletin, the OCC said:

  • Its filing decisions are governed by 12 CFR 5.13, a regulation that says the OCC may approve, conditionally approve, or deny a filing.

  • It is committed to acting on all filings in a timely manner appropriate to the nature and complexity of the filing, but it may return a filing without a decision if it finds the filing to be materially deficient.

  • It approves a filing when it finds the filer has favorably met the appropriate statutory, regulatory, and policy criteria related to the filing type.

  • When it finds a significant supervisory, Community Reinvestment Act, or compliance concern exists with respect to the filer, approval is inconsistent with law, regulation, or OCC policy, or the filer fails to provide requested information, the agency plans to deny the filing.

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