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Entity DossierGovernment Body

Office of the Comptroller of the Currency

Federal bank regulator that charters, regulates, and supervises national banks. Under Acting Comptroller Brian Brooks (2020-2021), issued interpretive letters enabling banks to custody crypto.

finance banking

Tracked direct giving

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Tracked donations to candidate

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Connections

157

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Regulatory Capture Assessment

Regulatory capture occurs when a regulatory agency advances the interests of the industry it is meant to oversee. The indicators below track evidence of capture for this agency. According to the academic literature (Stigler 1971, Carpenter & Moss 2013), captured agencies exhibit declining enforcement, revolving door personnel pipelines, and rule-making that favors incumbents over public interest.

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Enforcement actions
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Revolving door
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Relationships

TypeConnected ToDetailsSource
issued_rulePreemption Determination: State Interest-on-Escrow LawsIssued the rule.Source
proposed_ruleNational Bank and Federal Savings Association Digital ActivitiesOCC proposed rule: National Bank and Federal Savings Association Digital ActivitiesSource
issued_ruleReal Estate Lending Escrow AccountsIssued the rule.Source
issued_ruleOCC Guidelines Establishing Heightened Standards for Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches; Technical AmendmentsIssued the rule.Source
issued_ruleCommunity Reinvestment Act: Simplified Strategic Plan Process for Community BanksIssued the rule.Source
issued_ruleAppraisals for Higher-Priced Mortgage Loans Exemption ThresholdIssued the rule.Source
issued_ruleRegulatory Capital Rule: Modifications to the Enhanced Supplementary Leverage Ratio Standards for U.S. Global Systemically Important Bank Holding Companies and Their Subsidiary Depository Institutions; Total Loss-Absorbing Capacity and Long-Term Debt Requirements for U.S. Global Systemically Important Bank Holding CompaniesIssued the rule.Source
issued_ruleRegulatory Capital Rule: Revisions to the Community Bank Leverage Ratio FrameworkIssued the rule.Source
issued_ruleFinancial Data Transparency Act Joint Data StandardsIssued the rule.Source
issued_ruleCommunity Bank Licensing AmendmentsIssued the rule.Source
issued_ruleFair Housing Home Loan Data SystemIssued the rule.Source
shaped_policyRescission of OCC Guidelines Establishing Standards for Recovery Planning by Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal BranchesRepealed or rescinded the rule.Source
issued_ruleUnsafe or Unsound Practices, Matters Requiring AttentionIssued the rule.Source
issued_ruleProhibition on Use of Reputation Risk by RegulatorsIssued the rule.Source
issued_ruleRegulatory Publication and Review Under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Issued the rule.Source
issued_ruleCommunity Reinvestment Act RegulationsIssued the rule.Source
issued_ruleRegulatory Capital Rule: Modifications to the Enhanced Supplementary Leverage Ratio Standards for U.S. Global Systemically Important Bank Holding Companies and Their Subsidiary Depository Institutions; Total Loss-Absorbing Capacity and Long-Term Debt Requirements for U.S. Global Systemically Important Bank Holding CompaniesIssued the rule.Source
shaped_policyBusiness Combinations Under the Bank Merger Act; RescissionRepealed or rescinded the rule.Source
issued_ruleTemporary Exceptions to FIRREA Appraisal Requirements in Los Angeles County as Affected by California Wildfires and Straight-Line WindsIssued the rule.Source
issued_ruleNotification of Inflation Adjustments for Civil Money PenaltiesIssued the rule.Source
issued_ruleAnti-Money Laundering and Countering the Financing of Terrorism Program RequirementsIssued the rule.Source
issued_ruleQuality Control Standards for Automated Valuation ModelsIssued the rule.Source
issued_ruleRegulatory Publication and Review Under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Issued the rule.Source
issued_ruleRegulatory Publication and Review Under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Issued the rule.Source
issued_ruleOCC Guidelines Establishing Standards for Recovery Planning by Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal BranchesIssued the rule.Source
issued_ruleAppraisals for Higher-Priced Mortgage Loans Exemption ThresholdIssued the rule.Source
issued_ruleBusiness Combinations Under the Bank Merger ActIssued the rule.Source
issued_ruleInteragency Guidance on Reconsiderations of Value of Residential Real Estate ValuationsIssued the rule.Source
issued_ruleOCC Guidelines Establishing Standards for Recovery Planning by Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal BranchesIssued the rule.Source
issued_ruleBusiness Combinations Under the Bank Merger Act; Extension of Comment PeriodIssued the rule.Source
issued_ruleCommunity Reinvestment Act; Supplemental RuleIssued the rule.Source
issued_ruleTemporary Exceptions to FIRREA Appraisal Requirements in Maui County as Affected by Hawaii WildfiresIssued the rule.Source
issued_ruleBusiness Combinations Under the Bank Merger ActIssued the rule.Source
issued_ruleAvailability of Information Under the Freedom of Information ActIssued the rule.Source
issued_ruleRegulatory Publication and Review Under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Issued the rule.Source
issued_ruleCommunity Reinvestment ActIssued the rule.Source
issued_rulePreemption Determination: State Interest-on-Escrow LawsIssued the rule.Source
issued_ruleRegulatory Capital Rule: Community Bank Leverage Ratio FrameworkIssued the rule.Source
issued_ruleNational Bank Non-Interest Charges and FeesIssued the rule.Source
issued_ruleStreamlining Regulations Concerning Public Welfare Investments, Open Market Collateralized Loan Obligations, and Federal Savings Association Nondiscrimination RequirementsIssued the rule.Source
issued_ruleProhibition on the Use of Reputation Risk by RegulatorsIssued the rule.Source
issued_ruleAnti-Money Laundering and Countering the Financing of Terrorism ProgramsIssued the rule.Source
issued_ruleRegulatory Capital Rules: Regulatory Capital and Standardized Approach for Risk-Weighted AssetsIssued the rule.Source
issued_ruleRegulatory Capital Rule: Category I and II Banking Organizations, Banking Organizations With Significant Trading Activity, and Optional Adoption for Other Banking OrganizationsIssued the rule.Source
issued_ruleFair Housing Home Loan Data SystemIssued the rule.Source
issued_ruleRules of Practice and ProcedureIssued the rule.Source
issued_ruleAppraisals for Higher-Priced Mortgage Loans Exemption ThresholdIssued the rule.Source
issued_ruleLong-Term Debt Requirements for Large Bank Holding Companies, Certain Intermediate Holding Companies of Foreign Banking Organizations, and Large Insured Depository Institutions; Extension of Comment PeriodIssued the rule.Source
shaped_policyRescission of OCC Guidelines Establishing Standards for Recovery Planning by Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal BranchesRepealed or rescinded the rule.Source
issued_ruleRegulatory Capital Rule: Large Banking Organizations and Banking Organizations With Significant Trading Activity; Extension of Comment PeriodIssued the rule.Source
issued_ruleCommunity Bank Licensing AmendmentsIssued the rule.Source
issued_ruleNational Bank Community Development InvestmentsAmended an existing rule.Source
issued_ruleLong-Term Debt Requirements for Large Bank Holding Companies, Certain Intermediate Holding Companies of Foreign Banking Organizations, and Large Insured Depository InstitutionsIssued the rule.Source
issued_ruleRegulatory Capital Rule: Large Banking Organizations and Banking Organizations With Significant Trading ActivityIssued the rule.Source
issued_ruleInteragency Guidance on Reconsiderations of Value of Residential Real Estate ValuationsIssued the rule.Source
issued_ruleQuality Control Standards for Automated Valuation ModelsIssued the rule.Source
issued_ruleInteragency Policy Statement on Allowances for Credit Losses (Revised April 2023)Issued the rule.Source
EmploysBrian BrooksBrian Brooks served as Acting Comptroller of the Currency (May 2020-Jan 2021). Issued interpretive letters allowing banks to custody crypto and hold stablecoin reserves.Source
Overseen bySenate Banking CommitteeSenate Banking Committee has jurisdiction over the Office of the Comptroller of the CurrencyEditorial
EmploysJonathan GouldJonathan Gould nominated as Comptroller of the CurrencyEditorial
Overseen byHouse Financial Services CommitteeHouse Financial Services Committee has jurisdiction over the Office of the Comptroller of the CurrencyEditorial
commented_onNeighborWorks Collaborative of OhioPublic comment on OCC-2022-0002: Community Reinvestment ActSource
commented_onThai Community Development CenterPublic comment on OCC-2022-0002: Community Reinvestment ActSource
commented_onImpact Shares Corp / Impact Shares Affordable Housing MBS ETF (OWNS)Public comment on OCC-2022-0002: Community Reinvestment ActSource
commented_onRondo Community Land TrustPublic comment on OCC-2022-0002: Community Reinvestment ActSource
commented_onNeighborhood Housing Services of ChicagoPublic comment on OCC-2022-0002: Community Reinvestment ActSource
commented_onNeighborhoods, Inc. (dba NeighborWorks Lincoln)Public comment on OCC-2022-0002: Community Reinvestment ActSource
commented_onCommunity AdvocatesPublic comment on OCC-2022-0002: Community Reinvestment ActSource
commented_onCanandaigua National Bank & TrustPublic comment on OCC-2022-0002: Community Reinvestment ActSource
commented_onVIA Community DevelopmentPublic comment on OCC-2022-0002: Community Reinvestment ActSource
commented_onNon Profit Housing Association of Northern California (NPH)Public comment on OCC-2022-0002: Community Reinvestment ActSource
commented_onNational Housing Resource CenterPublic comment on OCC-2022-0002: Community Reinvestment ActSource
commented_onRebuild Local News Coalition (updated comments)Public comment on OCC-2022-0002: Community Reinvestment ActSource
commented_onCoachella Valley Housing CoalitionPublic comment on OCC-2022-0002: Community Reinvestment ActSource
commented_onCPAC Foundation's Center for Regulatory FreedomPublic comment on OCC-2023-0016: Regulatory Publication and Review under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Source
commented_onBetter MarketsPublic comment on OCC-2023-0016: Regulatory Publication and Review under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Source
commented_onAxos BankPublic comment on OCC-2023-0016: Regulatory Publication and Review under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Source
commented_onBloombergPublic comment on OCC-2024-0012: Financial Data Transparency Act Joint Data StandardsSource
commented_onRandolph-Brooks Federal Credit UnionPublic comment on OCC-2011-0001: Incentive-Based Compensation ArrangementsSource
commented_onBPI/ABA/FSF/SIFMAPublic comment on OCC-2011-0001: Incentive-Based Compensation ArrangementsSource
commented_onAmerican Family Voices, Americans for Financial Reform, As you Sow, et alPublic comment on OCC-2011-0001: Incentive-Based Compensation ArrangementsSource
commented_onCapitol Federal SavingsPublic comment on OCC-2023-0016: Regulatory Publication and Review under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Source
commented_onHousing Partnership NetworkPublic comment on OCC-2023-0016: Regulatory Publication and Review under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Source
commented_onSTRUCTURED FINANCE ASSOCIATIONPublic comment on OCC-2023-0016: Regulatory Publication and Review under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Source
commented_onAssociation of National Numbering Agencies BV/SRL (ANNA)Public comment on OCC-2024-0012: Financial Data Transparency Act Joint Data StandardsSource
commented_onDIDO SolutionsPublic comment on OCC-2024-0012: Financial Data Transparency Act Joint Data StandardsSource
commented_onMeridian Compensation PartnersPublic comment on OCC-2011-0001: Incentive-Based Compensation ArrangementsSource
commented_onHermes EOSPublic comment on OCC-2011-0001: Incentive-Based Compensation ArrangementsSource
commented_onNational Trust Community InvestmentPublic comment on OCC-2022-0002: Community Reinvestment ActSource
commented_onCommunity Development Bankers Association (CDBA)Public comment on OCC-2023-0016: Regulatory Publication and Review under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Source
commented_onAssociation of National AdvertisersPublic comment on OCC-2023-0016: Regulatory Publication and Review under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Source
commented_onCUSIP Global ServicesPublic comment on OCC-2024-0012: Financial Data Transparency Act Joint Data StandardsSource
commented_onDigital Token Identifier FoundationPublic comment on OCC-2024-0012: Financial Data Transparency Act Joint Data StandardsSource
commented_onApes Together StrongPublic comment on OCC-2024-0012: Financial Data Transparency Act Joint Data StandardsSource
commented_onDepository Trust & Clearing Corporation (DTCC)Public comment on OCC-2024-0012: Financial Data Transparency Act Joint Data StandardsSource
commented_onObject Management Group (OMG)Public comment on OCC-2024-0012: Financial Data Transparency Act Joint Data StandardsSource
commented_onTokenization SystemsPublic comment on OCC-2024-0005: Anti-Money Laundering and Countering the Financing of Terrorism Program RequirementsSource
commented_onACAMSPublic comment on OCC-2024-0005: Anti-Money Laundering and Countering the Financing of Terrorism Program RequirementsSource
commented_onGoverning for Impact, Americans for Financial Reform Education Fund, Center for LGBTQ Advancement & Research, et. alPublic comment on OCC-2011-0001: Incentive-Based Compensation ArrangementsSource
commented_onInsurance CoalitionPublic comment on OCC-2011-0001: Incentive-Based Compensation ArrangementsSource
commented_onNational Council of Asian Pacific Americans (NCAPA)Public comment on OCC-2022-0002: Community Reinvestment ActSource
commented_onCRA Arizona CoalitionPublic comment on OCC-2021-0014: Community Reinvestment Act RegulationsSource
commented_onIndependent Bankers Association of Texas (IBAT)Public comment on OCC-2021-0014: Community Reinvestment Act RegulationsSource
commented_onWashington Federal Bank, N.A. dba WaFd BankPublic comment on OCC-2020-0045: National Bank and Federal Savings Association PremisesSource
commented_onLocal Initiatives Support Corporation (LISC)Public comment on OCC-2023-0016: Regulatory Publication and Review under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Source
commented_onWoodstock InstitutePublic comment on OCC-2023-0016: Regulatory Publication and Review under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Source
commented_onAdvanced DynamicsPublic comment on OCC-2023-0016: Regulatory Publication and Review under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Source
commented_onNational Bank of HungaryPublic comment on OCC-2023-0016: Regulatory Publication and Review under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Source
commented_onSECURITIES INDUSTRY AND FINANCIAL MARKETS ASSOCIATION (SIFMA)Public comment on OCC-2024-0012: Financial Data Transparency Act Joint Data StandardsSource
commented_onSee attached letterPublic comment on OCC-2024-0012: Financial Data Transparency Act Joint Data StandardsSource
commented_onOccupy the SECPublic comment on OCC-2011-0001: Incentive-Based Compensation ArrangementsSource
commented_onMcGuireWoodsPublic comment on OCC-2011-0001: Incentive-Based Compensation ArrangementsSource
commented_onHousingLOUISIANA; HousingNOLA; Greater New Orleans Housing Alliance (GNOHA)Public comment on OCC-2022-0002: Community Reinvestment ActSource
commented_onBank of Southern CaliforniaPublic comment on OCC-2021-0014: Community Reinvestment Act RegulationsSource
commented_onLeague of United Latin American Citizens (LULAC)Public comment on OCC-2021-0014: Community Reinvestment Act RegulationsSource
commented_onDavenport, Evans, Hurwitz & SmithPublic comment on OCC-2020-0045: National Bank and Federal Savings Association PremisesSource
commented_onThe Financial Accountability and Corporate Transparency (FACT) CoalitionPublic comment on OCC-2020-0037: Exemptions to Suspicious Activity Report RequirementsSource
commented_onChicago Community Loan FundPublic comment on OCC-2023-0016: Regulatory Publication and Review under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Source
commented_onAMERICAN DENTAL ASSOCIATIONPublic comment on OCC-2023-0016: Regulatory Publication and Review under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Source
commented_onSouthwest Native Assets CoalitionPublic comment on OCC-2023-0016: Regulatory Publication and Review under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Source
commented_onAmerican Association of Bank DirectorsPublic comment on OCC-2023-0016: Regulatory Publication and Review under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Source
commented_onNational Consumer Law Center, on behalf of its low-income clientsPublic comment on OCC-2024-0005: Anti-Money Laundering and Countering the Financing of Terrorism Program RequirementsSource
commented_onMetro IAFPublic comment on OCC-2022-0002: Community Reinvestment ActSource
commented_onNeighborWorks AmericaPublic comment on OCC-2021-0014: Community Reinvestment Act RegulationsSource
commented_onThe Bank Policy InstitutePublic comment on OCC-2023-0016: Regulatory Publication and Review under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Source
commented_onNational Federation of Independent Business (NFIB)Public comment on OCC-2024-0012: Financial Data Transparency Act Joint Data StandardsSource
commented_onNational Minority Supplier Development Council (NMSDC)Public comment on OCC-2022-0002: Community Reinvestment ActSource
commented_onABA, BPI, CBA, MBA, ICBA, NAAHL, et alPublic comment on OCC-2021-0014: Community Reinvestment Act RegulationsSource
commented_onIndependent Community Bankers of AmericaPublic comment on OCC-2023-0016: Regulatory Publication and Review under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Source
commented_onAmerican Council on EducationPublic comment on OCC-2023-0016: Regulatory Publication and Review under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Source
commented_onCongress of the United StatesPublic comment on OCC-2024-0012: Financial Data Transparency Act Joint Data StandardsSource
commented_onGlobal Legal Entity Identifier Foundation (GLEIF)Public comment on OCC-2024-0012: Financial Data Transparency Act Joint Data StandardsSource
commented_onZion BankPublic comment on OCC-2011-0001: Incentive-Based Compensation ArrangementsSource
commented_onU.S. CongressPublic comment on OCC-2022-0002: Community Reinvestment ActSource
commented_onNational Digital Inclusion AlliancePublic comment on OCC-2021-0014: Community Reinvestment Act RegulationsSource
commented_onABA, BPI, IIB, SIFMAPublic comment on OCC-2020-0038: Computer-Security Incident Notification Requirements for Banking Organizations and their Bank Service ProvidersSource
commented_onNational Council of State Housing AgenciesPublic comment on OCC-2023-0016: Regulatory Publication and Review under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Source
commented_onFair Finance WatchPublic comment on OCC-2023-0016: Regulatory Publication and Review under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Source
commented_onOptions Clearing CorporationPublic comment on OCC-2024-0012: Financial Data Transparency Act Joint Data StandardsSource
commented_onAmericas Focus Committee of the Association of Global CustodiansPublic comment on OCC-2024-0012: Financial Data Transparency Act Joint Data StandardsSource
commented_onACTUS Financial Research FoundationPublic comment on OCC-2024-0012: Financial Data Transparency Act Joint Data StandardsSource
commented_onWells FargoPublic comment on OCC-2011-0001: Incentive-Based Compensation ArrangementsSource
commented_onSIFMA & BPIPublic comment on OCC-2011-0001: Incentive-Based Compensation ArrangementsSource
commented_onPublic CitizenPublic comment on OCC-2011-0001: Incentive-Based Compensation ArrangementsSource
commented_onOffice of the Treasurer & Tax Collector City & County of San FranciscoPublic comment on OCC-2021-0014: Community Reinvestment Act RegulationsSource
commented_onCDFI CoalitionPublic comment on OCC-2021-0014: Community Reinvestment Act RegulationsSource
commented_onMassachusetts Community & Banking CouncilPublic comment on OCC-2021-0014: Community Reinvestment Act RegulationsSource
commented_onNational Association of Affordable Housing LendersPublic comment on OCC-2023-0016: Regulatory Publication and Review under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Source
commented_onTRUIST FINANCIAL CORPORATION FEDERAL PAC (FORMERLY SUNTRUST BANKS, INC. POLITICAL ACTION COMMITTEE)Public comment on OCC-2023-0016: Regulatory Publication and Review under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Source
commented_onInternational BancsharesPublic comment on OCC-2023-0016: Regulatory Publication and Review under the Economic Growth and Regulatory Paperwork Reduction Act of 1996Source
commented_onWorkivaPublic comment on OCC-2024-0012: Financial Data Transparency Act Joint Data StandardsSource
commented_onInvestment Company InstitutePublic comment on OCC-2024-0012: Financial Data Transparency Act Joint Data StandardsSource
commented_onInvestment Adviser AssociationPublic comment on OCC-2024-0012: Financial Data Transparency Act Joint Data StandardsSource
commented_onDeconflictPublic comment on OCC-2024-0005: Anti-Money Laundering and Countering the Financing of Terrorism Program RequirementsSource
commented_onFirst Central Savings BankPublic comment on OCC-2024-0005: Anti-Money Laundering and Countering the Financing of Terrorism Program RequirementsSource
commented_on20/20 Vision, AFL-CIO, AFSCME, AFT, Americans for Financial Reform Education Fund, et. alPublic comment on OCC-2011-0001: Incentive-Based Compensation ArrangementsSource
commented_onAmerican ExpressPublic comment on OCC-2011-0001: Incentive-Based Compensation ArrangementsSource