Banking and Finance Law Daily Wrap Up, BANKING OPERATIONS—OCC clarifies standards for decisions on filings, (Jun 18, 2026)
Organizations Mentioned:Office of the Comptroller of the Currency
By Carrie DeLeon
The OCC warned this week that it will send back without a decision any incomplete applications or filings that are found to be materially deficient.
The Office of the Comptroller of the Currency released a bulletin this week to clarify the standards for its decisions on filings and further noted that it may approve, conditionally approve, or deny a filing (OCC Bulletin 2026-27). In addition, the OCC said it may return a filing as materially deficient in cases where it “lacks sufficient information for the OCC to make a determination under the applicable statutory or regulatory criteria.”
“This communication is to remind the public that the OCC strictly adheres to the regulation and to explain how the OCC implements it, which aligns with the agency’s historical practices,” the OCC said in the June 17 bulletin.
The OCC said that it is “paramount that filings contain all information necessary for the OCC to evaluate the filing as part of the initial submission.” Otherwise, the OCC said it will return a materially deficient filing before engaging in any “meaningful processing of the filing.” Information that is necessary to complete a review of a filing includes the biographical and financial information of individuals and corporate background and financial report for entities, OCC pointed out.
In addition, the OCC said it may return a filing if, after requesting additional information from the filer, the responses do not sufficiently respond to the requests. This includes instances where “organizers of a ‘de novo’ charter have not demonstrated that all products and services have been defined with particularity, including how they will be operationalized, or have not fully defined the associated governance, risk management, and compliance management infrastructure to manage these products and services,” according to the OCC’s bulletin.
If a filing is denied, the OCC said it must notify the applicant in writing of the reasons for the denial. In addition, the OCC said it will make all denial decisions public so that all stakeholders are aware of how the OCC has applied the decision criteria in that proposal. Despite the denial, an applicant will be allowed to file a subsequent application.
“Ultimately, it is important that the public understand how filings are decided under applicable laws, regulations, and policy,” OCC said.
In cases where the filer has “favorably met the appropriate statutory, regulatory and policy criteria related to the filing type,” the filing will be approved. In some cases, however, the OCC said it will condition an approval to ensure the filer will “operate in a safe and sound manner, consistent with OCC policy, and comply with applicable laws and regulations.”
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