US OCC’s Gould Testifies on Supervisory Reform Efforts

In testimony delivered before the US House of Representatives Committee on Financial Services, Comptroller of the Currency Jonathan Gould outlined how the Office of the Comptroller of the Currency is seeking to reform regulation and supervision, arguing that post-2008 regulation had made the banking system less relevant and diverse by seeking to eliminate rather than manage risk. 

Gould traced the problem to the Dodd-Frank Act, which he said created a “moat” around the largest banks while introducing what he described as “too-small-to-succeed.” This, he argued, has discouraged prudent risk-taking, reduced credit availability in many communities, and driven financial activity into less-regulated and less-visible parts of the economy. The number of community banks with less than $1 billion in total assets declined by 50 percent in the years that followed, Gould explained.

The OCC has introduced a series of reforms in response. Examinations have been tailored to actual risk, fixed examination requirements have been removed, and a dedicated supervision group has been created for community banks, Gould recounted. More broadly, the OCC is returning to risk-based oversight rooted in examiner judgment rather than “arbitrary checklists,” he said, hardwiring the definition of unsafe and unsound practices into regulation and reviewing past supervisory criticisms and enforcement actions for alignment with a material financial risk standard.

On de novo bank formation, which fell by 90 percent after 2008, Gould pointed to concrete signs of recovery. The OCC received as many charter applications in 2025 alone as in the previous four years, a full-service national bank opened its doors for the first time in five years, and 10 more have been conditionally approved this year.

Gould also identified stablecoin regulation under the GENIUS Act, revised model risk management guidance to avoid impeding banks’ use of AI, and an ongoing investigation into alleged debanking as key priorities. “[W]e, like the banking system itself, must always look towards the future,” he said. “Our job is to facilitate, not stymie, responsible innovation.”