Matter Requiring Attention (MRA)

An MRA is how examiners tell a bank, in writing, that something must be fixed. MRAs appear in the report of examination, set out the corrective action examiners expect, usually with a target date, and stay open until examiners confirm the fix. If the underlying problem persists and meets the higher enforcement standard, the agency can escalate to an enforcement action. Under the new rule, failing to clear an MRA is not by itself an unsafe or unsound practice.

In 2026 the OCC and FDIC finalized a rule redefining when a bank has engaged in an “unsafe or unsound practice” and when an MRA can be issued. An MRA now requires a practice contrary to generally accepted standards of prudent operation that could reasonably be expected, under current or reasonably foreseeable conditions, to materially harm the bank’s financial condition or present a material risk of loss to the Deposit Insurance Fund, or an actual violation of banking law. Weaknesses below that bar become nonbinding supervisory observations. The rule applies to OCC- and FDIC-supervised banks; the Federal Reserve is not a party.

For credit teams, the bar still reaches the work that matters most. Financial condition includes asset quality, so weak credit administration, unsupported risk ratings or poor underwriting can still draw an MRA when they could reasonably be expected to cause material harm. The agencies say the materiality bar is generally higher for community banks than for large banks. This Week in Credit Risk, September 9, 2026 covers the rule.