At a glance

Change Status Who it reaches First thing to do
OCC community bank BSA exam procedures In effect for exams beginning February 1, 2026 OCC-supervised banks up to $30 billion Make your independent test easy for an examiner to rely on
OCC allowances for credit losses booklet, version 2.0 Issued July 16, 2026 Banks of all sizes the OCC examines; the policy behind it is joint Check your allowance documents against the examiner questions
Proposed CAMELS rating revisions Proposal; comments closed in August; not final Banks and credit unions Know what would change in the management rating, and do not change anything yet
Proposed third-party risk management guidance Proposal; comments due November 16 Banks and credit unions Rank your vendors by potential harm and document the reasoning

The BSA exam procedures

The OCC’s Community Bank Procedures became the baseline for BSA/AML exams that began on or after February 1, 2026. Examiners may rely on a bank’s independent testing section by section, carry forward BSA officer and training conclusions for one cycle under set conditions, and decide how much transaction testing to do. The procedures cover only banks the OCC supervises. A state-chartered bank examined by the FDIC, the Federal Reserve or a state agency is not covered.

What to do. Scope your independent test clearly, keep workpapers that show what was sampled, and keep a record of changes to products, staff and systems.

The allowances for credit losses booklet

On July 16, 2026, the OCC issued version 2.0 of its booklet for examining allowances for credit losses. It reflects the April 2023 interagency policy statement, so the questions it raises apply to banks examined by any of the federal agencies. Examiners will want to see why each qualitative adjustment is sized as it is, who validated the process and whether that person is independent, and what the board approved.

What to do. Read your allowance policy against those questions, and write down the reasoning for each adjustment, including those that have not moved. Our free CECL and ACL readiness assessment is a quick way to see where you stand.

The CAMELS proposal

On May 19, 2026, the FFIEC agencies published proposed revisions to the Uniform Financial Institutions Rating System, which everyone calls CAMELS. The proposal keeps the composite rating and the six component ratings on a one-to-five scale. Its main changes would apply to management.

  • Three evaluation factors would be removed: management depth and succession, responsiveness to auditor and supervisory recommendations, and willingness to serve the community’s banking needs.
  • Management would generally receive a 3 or worse only when risk management weaknesses create material financial risk, or when reporting is unreliable, assets are not safeguarded or there is significant noncompliance.
  • The special weight management carries in the composite rating would be removed.
  • Findings from specialty reviews such as IT, BSA/AML and compliance would affect ratings only if they affect financial condition, pose material financial risk or reflect significant noncompliance.

Comments closed on August 17, 2026. The proposal is not final, and examiners still use the current system.

What to do. Do not rewrite anything yet. Understand how a rating is built today, since the current rules still apply to your next exam, and be ready to see how the final version treats management.

The third-party risk proposal

On September 11, 2026, the Federal Reserve, FDIC, OCC and NCUA proposed interagency third-party risk guidance that would replace the 2023 version. It asks banks to size oversight to the harm a relationship could cause, and says that failing to follow the guidance would not by itself lead to supervisory action. The Federal Reserve also proposed a companion guide for traditional community banks. Comments on both are due November 16, 2026.

What to do. Rank your vendors by how much harm a failure could cause and document why each gets the level of diligence it does. Consider commenting before November 16.

Why look at them together

The common thread is a move toward risk-based supervision. Each change asks examiners to scale their work to the bank’s actual risk and to rely more on the bank’s own documented reasoning. That rewards banks that can show their reasoning clearly and costs banks that cannot. A documented ranking of vendors, a written reason for each allowance adjustment, an independent test that examiners can rely on and a clear view of how ratings are built all do the same job: they let you show your work.