Office of the Comptroller of the Currency

Office of the Comptroller of the Currency
	Seal of the Office of the Comptroller of the Currency
	Logo of the Office of the Comptroller of the Currency
	; Flag of the Comptroller of the Currency
Agency overview
Formed	February 25, 1863; 161 years ago
Headquarters	Constitution Center, Washington, D.C.
Employees	3,518 (as of December 31, 2020)
Agency executive	Michael J. Hsu, Acting Comptroller;
Parent agency	Department of the Treasury
Website	www.occ.gov

The Office of the Comptroller of the Currency (OCC) is an independent bureau within the United States Department of the Treasury that was established by the National Currency Act of 1863 and serves to charter, regulate, and supervise all national banks and thrift institutions and the federally licensed branches and agencies of foreign banks in the United States.^[2] The acting Comptroller of the Currency is Michael J. Hsu, who took office on May 10, 2021.^[3]

Duties and functions

Headquartered in Washington, D.C., it has four district offices located in New York City, Chicago, Dallas and Denver. It has an additional 92 operating locations throughout the United States. It is an independent bureau of the United States Department of the Treasury and is headed by the Comptroller of the Currency, appointed to a five-year term by the President with the consent of the U.S. Senate.

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 was created by Abraham Lincoln to fund the American Civil War but was later transformed into a regulatory agency to instill confidence in the federal banking system, ensure it operates in a safe and sound manner, and treats customers fairly.

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,^[4] 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 a director of the Neighborhood Reinvestment Corporation, and the Federal Deposit Insurance Corporation and member of the 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.^[5] Despite opposition from the National Conference of State Legislatures,^[6] the OCC's regulations went into effect. In Watters v. Wachovia Bank, N.A. 550 U.S. 1 (2007), 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":

State regulators cannot interfere with the business of banking by subjecting national banks or their OCC-licensed operating subsidiaries to multiple audits and surveillance under rival oversight regimes.^[7]

In Cuomo v. Clearing House Association, L. L. C. 557 U.S. 519 (2009), 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).^[8]

HelpWithMyBank.gov

In July 2007, the OCC launched HelpWithMyBank.gov to assist customers of national banks and provide answers to national banking questions.^[9]

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.^[10]

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.^[11]

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.^[11]

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.^[12]^[2]

The OCC was involved in the response during and after the financial crisis of 2007–08, 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.^[13]

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).^[14] According to Marketplace, former acting Comptroller Keith Noreika and his successor, Joseph Otting, both used the latter pronunciation.^[15]

List of comptrollers of the currency

Administrator	Took office	Left office^[16]
Hugh McCulloch	February 25, 1863	March 9, 1865
Freeman Clarke	March 9, 1865	July 24, 1866
Hiland R. Hulburd	February 1, 1867	April 3, 1872
John Jay Knox Jr.	April 25, 1872	April 30, 1884
Henry W. Cannon	May 12, 1884	March 1, 1886
William L. Trenholm	April 20, 1886	April 30, 1889
Edward S. Lacey	May 1, 1889	June 30, 1892
A. Barton Hepburn	August 2, 1892	April 25, 1893
James H. Eckels	April 26, 1893	December 31, 1897
Charles G. Dawes	January 1, 1898	September 30, 1901
William Barret Ridgely	October 1, 1901	March 28, 1908
Lawrence O. Murray	April 27, 1908	April 27, 1913
John Skelton Williams	February 2, 1914	March 2, 1921
Daniel Richard Crissinger	March 17, 1921	March 30, 1923
Henry M. Dawes	May 1, 1923	December 17, 1924
Joseph W. McIntosh	December 20, 1924	November 20, 1928
John W. Pole	November 21, 1928	September 20, 1932
James Francis Thaddeus O'Connor	May 11, 1933	April 16, 1938
Preston Delano	October 24, 1938	February 15, 1953
Ray M. Gidney	April 16, 1953	November 15, 1961
James J. Saxon	November 16, 1961	November 15, 1966
William B. Camp	November 16, 1966	March 23, 1973
James E. Smith	July 5, 1973	July 31, 1976
John G. Heimann	July 21, 1977	May 15, 1981
Charles Lord (acting)	May 16, 1981	December 16, 1981
C. T. Conover	December 16, 1981	May 4, 1985
Robert L. Clarke	December 2, 1985	February 29, 1992
Stephen Steinbrink (acting)	March 1, 1992	April 5, 1993
Eugene Ludwig	April 5, 1993	April 3, 1998
Julie L. Williams (acting)	April 4, 1998	December 8, 1998
John D. Hawke Jr.	December 8, 1998	October 13, 2004
Julie L. Williams (acting)	October 14, 2004	August 4, 2005
John C. Dugan	August 4, 2005	August 14, 2010
John G. Walsh (acting)	August 15, 2010	April 9, 2012
Thomas J. Curry	April 9, 2012	May 5, 2017
Keith Noreika (acting)	May 5, 2017	November 27, 2017
Joseph Otting	November 27, 2017	May 29, 2020
Brian P. Brooks (acting)	May 29, 2020	January 14, 2021
Blake Paulson (acting)	January 14, 2021	May 10, 2021
Michael J. Hsu (acting)	May 10, 2021	present