Banking and Finance Law Daily Wrap Up, DEPOSIT INSURANCE—OCC’s Gould lays out priorities for role as FDIC board member, (Oct 8, 2025)

By Nora Macaluso

Deposit insurance, state bank preemption rights, and community banks are among the OCC head’s priorities for the FDIC.

In a statement issued at the Federal Deposit Insurance Corporation’s board meeting, Comptroller of the Currency Jonathan V. Gould said he will focus on areas including resolution execution capabilities, the Deposit Insurance Fund, and agency culture in his capacity as a Federal Deposit Insurance Corporation board member. The OCC and FDIC are working together on “several interagency initiatives,” according to Gould, who said he will use both his roles “to advance the President’s agenda.”

Gould listed the following FDIC-specific priorities:

Rebuilding resolution execution capabilities. Gould said he’s “skeptical of the efficacy” of resolution planning, which he defined as “the hypothetical exercise of how an organization would or should fail.”

“On the other hand, resolution execution is one of the FDIC’s core functions, and I will be focused on ensuring that the FDIC has the capabilities to carry out these core functions effectively,” he said. Looking at the FDIC’s actions in the wake of the 2023 bank failures “should inform our efforts to improve its resolution execution in the future,” he said.

Management of the Deposit Insurance Fund. “The methodologies employed by the agency to calculate insurance premiums or determine ratings that affect premiums, whether in the ordinary course or for special assessments, have, at times, lacked clarity and have spawned litigation, gaming or both,” said Gould. “Insurance premiums should be clear, fair, and designed to limit market distortions.”

Agency culture. Gould said he will support FDIC Acting Chairman Travis Hill’s efforts to “restore a culture of accountability” at the agency. The FDIC “has already taken a number of steps” to “address past abuses,” he said.

Deposit insurance applications. The FDIC’s approach to chartering new banks “needs to change if we want to restore a dynamic banking system,” Gould said.

“As the statutory factors for granting deposit insurance are largely taken into account by the chartering authority, the FDIC should perform a circumscribed review, as it did in the years following the enactment of FDICIA,” he said.

“The OCC is committed to collaborating with the FDIC to align and improve upon our de novo bank application process,” he said, adding that it is “vitally important for all federal banking agencies to have clear and transparent application processes with established timeframes that are actually followed absent extraordinary circumstances, whether for chartering, deposit insurance, business combinations, or other applications.”

State bank preemption rights. State banks are “on parity with national banks” regarding preemption of state laws affecting host state branches, Gould said. “Similarly, state banks benefit from interest rate preemption under Section 27 of the FDI Act,” he said. “State banks should get the benefit of this federal preemption, and I encourage the FDIC to take additional steps to support these Congressionally-granted rights.”

Bank funding. “The FDIC, like the OCC, still utilizes funding and deposit categories that do not have clear predictive value when it comes to managing liquidity risk,” said Gould. “We should re-examine these antiquated notions and develop a more flexible predictive framework going forward, including for assessments.”

Supporting community banks. “For too long, regulation and supervision have been insufficiently tailored for community banks, which has hampered their ability to serve our communities and drive economic growth,” said Gould. The FDIC and OCC are “taking steps to deliver relief on this front,” he said.

RegulatoryActivity: BankingOperations CommunityDevelopment DepositInsurance DirectorsOfficersEmployers FinancialStability Preemption PrudentialRegulation Receiverships StateBankingLaws