This Week in Credit Risk: The OCC and FDIC Narrow the Scope of MRAs
New OCC and FDIC rules redefine “unsafe or unsound practice” and narrow when examiners can issue a Matter Requiring Attention. Plus cyber risk and newly public CRA evaluations.
The OCC and FDIC finalized rules redefining when a bank has engaged in an “unsafe or unsound practice” and when examiners can issue a Matter Requiring Attention. Published in the Federal Register on September 1 and effective November 2, the rules limit MRAs to practices that could reasonably be expected to materially harm a bank’s financial condition, or to actual violations of law.
What Is a Matter Requiring Attention Under the New Rule?
MRAs are now limited to practices that could reasonably be expected, under current or reasonably foreseeable conditions, to materially harm the bank’s financial condition, or that are actual violations of law. Weaknesses below that bar become nonbinding supervisory observations.
The rule takes effect November 2 and applies to banks the OCC and FDIC supervise; the Federal Reserve is not a party. It cuts both ways. Minor procedural issues should no longer become MRAs, but weak credit administration can still draw one, because financial condition includes asset quality. Credit analysis, risk ratings and underwriting quality matter as much as ever.
The OCC’s 2026 Cybersecurity Report
The OCC’s 2026 Cybersecurity and Financial System Resilience Report, released in June, is worth a read if you have not seen it.
CRA Evaluations Made Public
On September 1 the OCC released a list of 23 CRA performance evaluations of national banks and federal savings associations that became public in August. If your institution is coming up for a CRA review, now is a good time to benchmark against peers.
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What is a Matter Requiring Attention (MRA)?
An MRA is a finding examiners issue when they identify a deficiency a bank must correct. Under the new OCC and FDIC rules, an MRA is limited to practices that could reasonably be expected to materially harm the bank’s financial condition, or to violations of law.
How do the new MRA rules affect credit teams?
Minor procedural issues become nonbinding observations, while weaknesses that could materially harm financial condition, including weak credit administration, can still draw an MRA. The substance of credit analysis, risk ratings and underwriting matters as much as ever.
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Last updated September 9, 2026.