Office of the Comptroller of the Currency

Duties and functions

The OCC is one of the United States' federal banking regulators, with primary prudential authority over all national banks. There are two other federal regulators, the Federal Deposit Insurance Corporation and the Federal Reserve. The agency is headquartered in Washington, D.C. with four district offices located in New York City, Chicago, Dallas and Denver. It is an independent bureau of the United States Department of the Treasury. The official head of the agency is the Comptroller of the Currency, who is appointed to a five-year term by the President with the consent of the Senate. The agency's budget is not congressionally appropriated, being paid for by assessment fees levied on regulated banks.

The OCC pursues a number of main objectives:

• to ensure the safety and soundness of the national banking system;
• to foster competition by allowing banks to offer new products and services;
• to improve the efficiency and effectiveness of OCC supervision especially to reduce the regulatory burden;
• to ensure fair and equal access to financial services to all Americans;
• to enforce anti-money laundering and anti-terrorism financing laws that apply to national banks and federally licensed branches and agencies of international banks; and
• to investigate misconduct committed by institution-affiliated parties of national banks, including officers, directors, employees, agents and independent contractors (including appraisers, attorneys and accountants).

The OCC participates in interagency activities in order to maintain the integrity of the federal banking system. By monitoring capital, asset quality, management, earnings, liquidity, sensitivity to market risk, information technology, consumer compliance, and community reinvestment, the OCC is able to determine whether or not the bank is operating safely and soundly, providing fair access and treatment to customers, and complying with all applicable laws and regulations.

The OCC regulates and supervises about 1,200 national banks, federally-licensed savings associations, and federally-licensed branches of foreign banks in the United States, accounting for more than two-thirds of the total assets of all U.S. commercial banks (as of September 30, 2020).

Other financial regulatory agencies like the OCC include the Federal Deposit Insurance Corporation (of which the comptroller serves as a director), the Federal Reserve, the Consumer Financial Protection Bureau, and the National Credit Union Administration. The OCC routinely interacts and cooperates with other government agencies, including the Consumer Financial Protection Bureau, Financial Crimes Enforcement Network, the Office of Foreign Asset Control, the Federal Bureau of Investigation, the U.S. Department of Justice, and the Department of Homeland Security.

The Comptroller serves as an ex officio board member of the Neighborhood Reinvestment Corporation, Federal Deposit Insurance Corporation, Financial Stability Oversight Council, and the Federal Financial Institutions Examination Council.

Preemption of state banking regulation

In 2003, the OCC proposed regulations to preempt virtually all state banking and financial services laws for national banks and their diverse range of non-bank, corporate operating subsidiaries. Despite opposition from the National Conference of State Legislatures, the OCC's regulations went into effect. In Watters v. Wachovia Bank, N.A. , the United States Supreme Court validated the preemption of state regulations by the OCC, ruling that the OCC, not the states, has the authority to subject national banks to "general supervision" and "oversight":

In Cuomo v. Clearing House Association, L. L. C. , the Court clarified its decision in Watters, stating that federal banking regulations did not preempt the ability of states to enforce their own fair-lending laws, as general supervision and control' and 'oversight' are worlds apart from law enforcement", and therefore states retain law enforcement powers but have restricted "visitorial" powers over national banks (i.e., the right to examine the affairs of a corporation).

HelpWithMyBank.gov

In July 2007, the OCC launched HelpWithMyBank.gov to assist customers of national banks and provide answers to national banking questions.

Financial inclusion

On July 10, 2020, the OCC announced the launch of Project REACh. REACh stands for Roundtable for Economic Access and Change, and the project brings together leaders from the banking industry, national civil rights organizations, business, and technology to reduce specific barriers that prevent full, equal, and fair participation in the nation's economy.

History

During the American Civil War, leaders of the U.S. federal government, including President Abraham Lincoln and Treasury Secretary Salmon P. Chase, drafted plans for a national banking system. These plans were put into action by the National Currency Act of 1863, subsequently amended by the National Bank Act, which created the Office of the Comptroller of the Currency to administer the new system. Hugh McCulloch, former president of the state-owned Bank of Indiana, was chosen to be the first comptroller of the currency.

Under the law, banks could apply to the OCC for a charter issued by the federal government. Approved banks would purchase U.S. government bonds, generating cash flow for the government. The bonds would then be deposited with the U.S. Treasury to provide security to back the paper money to be issued by the banks, a new uniform United States currency that could be redeemed for gold or silver at banks around the country. By ensuring the new currency was backed by the government-held bonds, the system gave users greater confidence in the stability of the paper money.

By 1868, the OCC had 72 staff, a third of them women. They processed charter applications and distributed currency to national banks. Until 1913, these staff were paid by distance distributed and did not have set salaries.

In 1913, the Federal Reserve Act established a central bank, the Federal Reserve, to issue American currency. The OCC's role shifted to bank examination and regulation, though it retained "currency" as part of its name. In response to the growing power of local banks, the OCC insisted on deregulating national banks in order to compete, which was realized in the McFadden Act of 1927. In 1937, the OCC signed an agreement with the Federal Reserve and the Federal Deposit Insurance Corporation to standardize the regulation of banks between the agencies.

In the 1960s, 21st comptroller James J. Saxon passed a number of controversial regulations, including one which allowed national banks to underwrite revenue bonds for the governments of states and municipalities. Many of these were later overturned in court. However, some reforms, like creating international banking and economics units and strengthening the law department, remained after his term.

The OCC was involved in the response during and after the 2008 financial crisis, including work with the Troubled Asset Relief Program (TARP), designing stress tests for major banks, and collecting and analyzing data on home mortgage loans. The Dodd–Frank Wall Street Reform and Consumer Protection Act of 2010 abolished the Office of Thrift Supervision and merged its former oversight functions into the OCC. The law also reassigned much of the OCC's former compliance mandate to the new Consumer Financial Protection Bureau. It further established the Financial Stability Oversight Council, on which the Comptroller of the Currency sits.

Pronunciation

As with other uses of the English word "comptroller" there is some ambiguity about the agency's pronunciation. Historically, the word was pronounced identically to "controller," though it is increasingly pronounced as it is spelled (that is, comp-troller). According to Marketplace, former acting comptroller Keith Noreika and his successor, Joseph Otting, both used the latter pronunciation.

List of comptrollers of the currency

Since 1863, the following persons have served as the Comptroller of the Currency:

References

Bibliography

References

1. "Technical Supplement to the 2026 Budget: Appendix". Office of Management and Budget.
2. Van Loo, Rory. (August 1, 2018). "Regulatory Monitors: Policing Firms in the Compliance Era". Faculty Scholarship.
3. {{CodeFedReg. 12. 4. 4 (on headquarters); {{CodeFedReg. 12. 4. 5. b, noting four districts (the Northeastern, Central, Southern, and Western districts) with corresponding offices.
4. (October 2021). "Comptroller of the Currency". Cornell Law School.
5. (January 24, 2019). "Office of the Comptroller of the Currency About Us". OCC.gov.
6. {{CodeFedReg. 12. 4. 3 (2011).
7. "Proposed Rules : Federal Register Vol 68 No. 150". Edocket.access.gpo.gov.
8. [http://www.ncsl.org/standcomm/scfin/occ031006.htm] {{webarchive. link. (October 15, 2008)
9. {{cite court. (2007). [link]({{SCOTUS URL Slip). 06. 05-1342
10. {{cite court. (2009). [link]({{SCOTUS URL Slip). 08. 08-453
11. "Help and Frequently Asked Questions about National Banks from OCC's". Helpwithmybank.gov.
12. OCC (July 10, 2020). "[https://occ.gov/news-issuances/news-releases/2020/nr-occ-2020-89.html Announces Project REACh to Promote Greater Access to Capital and Credit for Underserved Populations]." Retrieved July 10, 2020.
13. (2011). "Office of the Comptroller of the Currency: A Short History". US Department of the Treasury.
14. (2019-01-14). "Founding of the OCC & the National Banking System".
15. (2019-02-26). "1914 - 1935".
16. (2019-03-14). "2008 - Present".
17. Cannadine, David. (2008). "Parliament: Past History, Present History, Future History". Palgrave Macmillan UK.
18. Dolnick, Sam. (2010-09-28). "A Job Title That Adds Confusion". The New York Times.
19. (2018-05-14). "You say comptroller, I say controller".
20. (November 29, 2022). "Previous Comptrollers of the Currency". OCC.
21. (August 27, 2024). "Previous Acting Comptrollers of the Currency". OCC.
22. (January 24, 2019). "Previous Comptrollers of the Currency".
23. "Hugh McCulloch". OCC.
24. "Freeman Clarke". OCC.
25. "Hiland R. Hulburd". OCC.
26. "John Jay Knox". OCC.
27. "Henry W. Cannon". OCC.
28. "William L. Trenholm". OCC.
29. "Edward S. Lacey". OCC.
30. "A. Barton Hepburn". OCC.
31. "James H. Eckels". OCC.
32. "Charles G. Dawes". OCC.
33. "William Barret Ridgely". OCC.
34. "Lawrence O. Murray". OCC.
35. "John Skelton Williams". OCC.
36. "D.R. Crissinger". OCC.
37. "Henry M. Dawes". OCC.
38. "Joseph W. McIntosh". OCC.
39. "John W. Pole". OCC.
40. "J.F.T. O'Connor". OCC.
41. "Preston Delano". OCC.
42. "Ray M. Gidney". OCC.
43. "James J. Saxon". OCC.
44. "William B. Camp". OCC.
45. "Justin T. Watson". OCC.
46. "James E. Smith". OCC.
47. "Robert L. Bloom". OCC.
48. "John G. Heimann". OCC.
49. "Charles E. Lord". OCC.
50. "C. Todd Conover". OCC.
51. "H. Joe Selby". OCC.
52. "Robert L. Clarke". OCC.
53. "Stephen R. Steinbrink". OCC.
54. "Eugene A. Ludwig". OCC.
55. "Julie L. Williams". OCC.
56. "John D. Hawke, Jr.". OCC.
57. "John C. Dugan". OCC.
58. "John G. Walsh". OCC.
59. "Thomas J. Curry". OCC.
60. "Keith A. Noreika". OCC.
61. "Joseph M. Otting". OCC.
62. "Brian P. Brooks". OCC.
63. "Blake Paulson". OCC.
64. "Michael J. Hsu". OCC.
65. "Rodney E. Hood". OCC.
66. (July 15, 2025). "Jonathan V. Gould Takes Office as the 32nd Comptroller of the Currency". Office of the Comptroller of the Currency.