Recent Office of the Comptroller of the Currency (OCC) announcements support community banks by reducing regulatory burdens, reflecting the agency’s efforts to align its supervisory frameworks with the size and risk profile of an institution.
In an announcement regarding the changes, Comptroller of the Currency Jonathan V. Gould noted, “Community banks provide the majority of small business lending and are essential to a diverse, competitive and resilient financial system. Today’s actions further relieve community banks of unnecessary regulatory requirements and seek to better position them to help fuel job creation and economic development in local communities across the country.”
BSA/AML Begins Feb. 1, 2026: What Community Banks Need to Know
The new Community Bank Minimum Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Procedures, announced Nov. 24, 2025, and effective Feb. 1, 2026, reduce burdens on community banks by emphasizing examiner discretion to:
- Rely on satisfactory independent testing to form a basis for conclusions for specific examination procedures.
- Carry forward prior examination conclusions for the training and BSA Compliance Officer pillars for one examination cycle when there have not been significant changes to the bank’s risk profile and in consideration of other relevant factors.
- Determine whether and to what extent to perform transaction testing, or if it’s appropriate to limit testing to analytical or other reviews.
New BSA/AML: What to Expect from Examiners
The new Community Bank Minimum Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Procedures focus examiners on three primary objectives:
- Scoping and Planning
Examiners will develop an understanding of the bank’s money laundering/terrorist financing (ML/TF) and other illicit financial activity risk profile, develop a risk-focused examination scope, and document the BSA/AML examination plan. - BSA/AML Compliance
Examiners will determine whether the bank has designed, implemented, and maintains an adequate BSA/AML compliance program that meets BSA regulatory requirements. - Develop Conclusions and Finalize the Examination
Using the bank’s risk profile and overall compliance with BSA regulatory requirements, examiners will determine the adequacy of the bank’s BSA/AML compliance program, and document and communicate examination findings to the bank.
MLR Revisions: No More Annual Mandatory Data Required, Input Requested
The OCC also announced that as of Nov. 24, 2025, it has discontinued annual mandatory data collection from community banks under the Money Laundering Risk (MLR) System.
It also issued a request for information (RFI) to help the OCC better understand the challenges community banks face with core service providers and other essential third-party service providers in areas like contract negotiations and terms, billing practices, oversight, due diligence, core and legacy system conversions, and data access.
The RFI includes questions regarding potential OCC actions that could address these challenges, such as reduced burdens related to supervisory practices, policies, and guidance. The comment period closed in January 2026, and the Rehmann team continues to monitor outcomes of the OCC final report.
Changes to CBLR Framework Proposed
Finally, the OCC noted that its ongoing work includes a proposal to reduce the community bank leverage ratio (CBLR) requirements. The comment period for the proposed amendments ends Jan. 30, 2026; further details, including potential implementation timelines, are expected to come in early to mid-2026.
Your Takeaway
Regulatory and compliance burdens are rapidly evolving, with many changes that stand to benefit smaller and mid-sized community banks. Bank boards should invest the time now to understand current, pending, and proposed updates that could significantly impact their organization’s strategic planning, growth, compliance, and merger & acquisition decisions. To help your board or organization navigate these and other changes, contact your Rehmann advisor or Beth Behrend, CCBCO, CBAP, at [email protected] or 616.975.4100 or Mynesha Phifer, CCBCO, at [email protected] or 734.302.4152.