OCC Regulatory Oversight Shifts: What Florida Community Banks Must Know and Do Now
The Office of the Comptroller of the Currency is making its most significant community bank-friendly regulatory moves in years — and Florida community banks and credit unions that understand these changes will have a meaningful strategic and competitive advantage over those that do not. At Kal Onomato, our financial management advisory team helps Florida banking institutions translate regulatory shifts into concrete financial strategy, compliance frameworks, and growth plans.
Three Major OCC Changes Florida Community Banks Must Understand in 2026
In a series of announcements beginning November 2025, Comptroller of the Currency Jonathan V. Gould signaled a clear directional shift in how the OCC approaches community bank supervision. As Gould stated: “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.”
For Florida community banks, this is not background noise — it is a direct invitation to revisit compliance burdens, adjust strategic planning assumptions, and engage proactively with pending proposals that could materially affect your capital requirements and operational costs. Our full-service advisory team and tax and accounting specialists help Florida banking institutions build the financial frameworks needed to act on these changes effectively.
New Community Bank BSA/AML Minimum Examination Procedures
Announced Nov. 24, 2025. Reduces exam burden by emphasizing examiner discretion, carry-forward conclusions, and risk-scaled transaction testing for qualifying community banks.
MLR System Annual Data Collection Discontinued
The OCC ended mandatory annual data collection under the Money Laundering Risk System. Combined with an open RFI on third-party service provider challenges, this signals broader community bank relief ahead.
CBLR Framework Reduction Proposed
The OCC proposed reducing Community Bank Leverage Ratio requirements. The comment period closed Jan. 30, 2026. Implementation details and timelines are expected in early to mid-2026 — with significant implications for capital planning.
New BSA/AML Examination Procedures: What Florida Banks Can Expect from Examiners
The new Community Bank Minimum BSA/AML Examination Procedures, effective February 1, 2026, represent a meaningful structural reduction in compliance burden for qualifying Florida community banks. The core principle is examiner discretion calibrated to each bank’s actual risk profile — rather than a one-size-fits-all checklist approach that treated a $200 million community bank the same as a $20 billion regional institution. Our compliance and financial advisory team helps Florida banking institutions prepare their compliance documentation, independent testing records, and risk-profile materials to maximize the benefit of these new procedures.
Developing a Risk-Focused Examination Scope
Examiners will begin by developing a thorough understanding of your bank’s money laundering, terrorist financing, and illicit financial activity risk profile — specific to your institution’s size, markets, products, and customer base. Based on that profile, they will develop a risk-focused examination scope and document a formal BSA/AML examination plan. Florida community banks with well-documented, current risk assessments will shape a more targeted and efficient examination scope from the outset.
Evaluating Whether Your Program Meets BSA Regulatory Requirements
Examiners will assess whether your bank has designed, implemented, and actively maintains an adequate BSA/AML compliance program that meets all BSA regulatory requirements. Under the new procedures, examiners have explicit discretion to rely on satisfactory independent testing results when forming conclusions — reducing redundant testing for banks with strong, documented compliance programs. The quality and currency of your independent BSA testing program directly affects how broad or narrow this examination phase will be.
Determining Compliance Program Adequacy and Communicating Findings
Using the bank’s risk profile and overall BSA regulatory compliance record, examiners will determine the adequacy of the bank’s BSA/AML compliance program and communicate findings formally. A critical new feature: examiners may carry forward prior examination conclusions for the training and BSA Compliance Officer pillars for one full examination cycle — provided there have been no significant changes to the bank’s risk profile. This carry-forward provision directly reduces the examination burden for stable, well-managed Florida community banks.
Three Key Examiner Discretion Provisions Florida Banks Must Leverage
The new procedures explicitly expand examiner discretion in three ways that Florida community banks should actively prepare to benefit from. The key is having the documentation and program quality in place to support each discretion provision before the examination begins — not scrambling to assemble it during the exam. Our advisory team conducts pre-examination readiness reviews for Florida banking clients to ensure every discretion provision is fully supported.
Rely on Independent Testing Results
Examiners may now rely on satisfactory independent testing to form the basis for examination conclusions on specific procedures — rather than re-performing testing themselves. Florida banks with rigorous, well-documented independent BSA testing programs are directly positioned to benefit. The quality of your independent testing documentation is now a direct lever on examination efficiency.
Carry Forward Prior Conclusions for One Cycle
For the training pillar and BSA Compliance Officer pillar, examiners may carry forward satisfactory conclusions from the prior examination cycle — provided the bank’s risk profile has not changed significantly. Florida community banks that maintain consistent risk profiles, stable compliance programs, and thorough change-management documentation are best positioned to benefit from this provision.
Scale or Limit Transaction Testing
Examiners now have explicit authority to determine whether and to what extent to perform transaction testing — including the option to limit testing to analytical or other reviews rather than full transaction sampling. For Florida community banks with clean prior examination records, stable risk profiles, and strong automated monitoring, this discretion provision can meaningfully reduce the time and documentation burden of each examination cycle.
🌟 How Florida banks maximize benefit from these discretion provisions: The examiner discretion built into the new BSA/AML procedures is not automatic — it is earned by banks that have invested in strong, documented, independently-tested compliance programs. Florida community banks that maintain current risk assessments, conduct rigorous independent testing, document their BSA Compliance Officer qualifications, and track program changes systematically are best positioned to see reduced examination burden under the new framework. Our advisory team helps Florida banking clients build the compliance documentation infrastructure that makes examiner discretion a realistic outcome — not just a theoretical possibility.
MLR Annual Data Collection Discontinued — and a Third-Party RFI That Matters
Effective November 24, 2025, the OCC discontinued mandatory annual data collection from community banks under the Money Laundering Risk System. This is a direct and immediate reduction in compliance burden for Florida community banks that have been completing these submissions annually — and it reflects the OCC’s broader effort to eliminate data collection requirements that do not meaningfully improve supervisory outcomes for institutions with strong risk management programs.
📋 Third-party service provider challenges — Florida banks should monitor OCC outcomes closely. Alongside the MLR discontinuation, the OCC issued a Request for Information to better understand the challenges community banks face with core service providers and other essential third parties — including contract negotiations, billing practices, oversight burden, due diligence requirements, core and legacy system conversions, and data access. The comment period closed in January 2026. The OCC’s final report and any resulting guidance changes could directly affect how Florida community banks manage their core banking relationships, vendor contracts, and technology infrastructure investments. Our financial advisory team monitors OCC guidance developments and helps Florida banking clients assess the operational and financial implications as they are released.
Proposed CBLR Reduction: Capital Planning Implications for Florida Community Banks
The OCC’s proposed reduction to the Community Bank Leverage Ratio framework is the most strategically significant pending change for Florida community bank capital planning. The CBLR is the simplified capital ratio framework available to qualifying community banks — allowing them to demonstrate capital adequacy with a single leverage ratio rather than the full suite of risk-weighted capital requirements that apply to larger institutions. A reduction in the CBLR threshold would directly affect how Florida community banks deploy capital, evaluate merger and acquisition opportunities, and manage growth decisions.
The comment period for the proposed amendments closed January 30, 2026. Implementation details and timelines are expected in early to mid-2026. Our CFO advisory team is actively modeling CBLR scenarios for Florida community bank clients to ensure that when the final rule is announced, every affected institution is prepared to act — not catching up.
Nov. 24, 2025
CBLR reduction proposed. BSA/AML procedures & MLR discontinuation announced.
Jan. 30, 2026
Comment period for proposed CBLR amendments closes. RFI comment period also closed.
Feb. 1, 2026
New Community Bank BSA/AML Minimum Examination Procedures take effect.
Mid-2026
CBLR final rule & OCC third-party RFI report expected. Capital planning decisions due.
⚠️ Board-level strategic review is required now — not after the final CBLR rule is published. Florida community bank boards should not wait for the OCC to finalize the CBLR reduction before modeling its implications for their institution. The range of proposed changes, and the outcomes most likely based on public comments, are knowable now. Boards that begin capital scenario planning immediately — including modeling the impact on M&A capacity, loan growth headroom, and dividend policy — will be positioned to make strategic decisions within days of the final rule, rather than spending weeks in catch-up analysis. Our CFO advisory and financial management team builds these multi-scenario capital models for Florida community bank clients as part of our ongoing advisory relationship.
Strategic Action Plan: What Florida Community Bank Boards Should Do Right Now
These OCC changes create both immediate compliance relief and medium-term strategic planning obligations for Florida community bank leadership. The table below maps each change to the specific board-level and management-level actions our financial advisory team recommends for Florida banking institutions in the current environment. Visit our advisory blog and client stories page for additional context on how we work with financial institutions.
| OCC Change | Effective | Florida Bank Action Required | Priority |
|---|---|---|---|
| New BSA/AML Exam Procedures | Feb. 1, 2026 | Update independent testing documentation; review risk assessment currency; brief BSA Compliance Officer on discretion provisions | Immediate |
| Examiner carry-forward provision | Feb. 1, 2026 | Document stability of risk profile; ensure prior exam conclusions are readily accessible; flag any changes triggering exclusion | Immediate |
| Transaction testing discretion | Feb. 1, 2026 | Strengthen automated monitoring documentation; maintain clean prior exam record to support limited testing elections | Near-term |
| MLR annual data collection ended | Nov. 24, 2025 | Remove from compliance calendar; reallocate staff time to higher-value compliance activities; confirm no state-level MLR equivalent applies | Complete |
| Third-party RFI outcomes | Results: Mid-2026 | Monitor OCC final report; assess implications for core vendor contracts, data access terms, and conversion planning | Monitor |
| CBLR framework reduction | Decision: Mid-2026 | Begin capital scenario modeling now across proposed reduction range; model M&A, lending growth, and dividend implications before final rule | Urgent — Plan Now |
How Kal Onomato Supports Florida Community Banks Through Regulatory Change
At Kal Onomato, our licensed CPA and financial advisory team brings 15+ years of experience to the compliance, tax, and strategic financial challenges of Florida financial institutions. We work with community banks, credit unions, and community development financial institutions to build proactive regulatory compliance frameworks, capital planning models, and strategic financial plans that are aligned with where regulation is heading — not just where it has been. Our work is fully aligned with IRS requirements for Florida-based financial institutions and Florida state accounting and reporting standards, and draws on best practices from recognized public finance frameworks (https://www.jmco.com/industries/government/).
- BSA/AML compliance program readiness review — our advisory team conducts pre-examination readiness assessments for Florida community banks, reviewing independent testing documentation, risk assessment currency, training records, and BSA Compliance Officer qualification documentation to ensure your program is positioned to benefit from every examiner discretion provision in the new procedures.
- CBLR capital scenario modeling — our CFO advisory team builds multi-scenario capital models for Florida community banks across the range of proposed CBLR reductions — showing the impact on loan growth capacity, M&A flexibility, dividend policy, and capital deployment strategy before the final rule is published.
- Third-party vendor contract and oversight strategy — in anticipation of OCC guidance from the third-party RFI, our financial management advisory team helps Florida community banks assess their current core vendor relationships, contract terms, and data access positions — identifying areas where incoming guidance may create leverage for renegotiation or risk reduction.
- Tax strategy for community bank operations — our tax planning team coordinates community bank tax strategy with capital planning, regulatory capital requirements, and OBBB provisions — including the bonus depreciation, R&D expensing, and Section 163(j) interest deductibility changes that directly affect Florida financial institution tax positions in 2026.
- AI-powered regulatory and financial monitoring — our AI financial platform monitors regulatory guidance updates, capital ratio movements, and compliance calendar milestones continuously — alerting our team and yours when any metric or upcoming deadline requires board or management attention before it becomes a compliance or strategic planning gap.
🤖 Regulatory Change Is a Strategic Opportunity — If You Act Before the Deadline
The OCC’s community bank-focused changes are not just compliance news — they are a strategic signal. Reduced examination burden, discontinued mandatory data collection, and a proposed reduction in capital requirements create room for Florida community banks to redirect resources toward growth, lending, and community investment. But the banks that benefit most are the ones that build the compliance infrastructure to earn examiner discretion, and the capital models to act on CBLR changes the moment the final rule is published. Our full-service advisory team and AI financial platform help Florida community banks do both. Schedule your free consultation today →
Frequently Asked Questions for Florida Community Bank Leaders
Is Your Florida Community Bank Ready to Act on These OCC Changes?
Book a free 30-minute consultation with Kal. We will review your BSA/AML compliance program readiness, build an initial CBLR capital scenario for your institution, and outline a clear action plan for every pending OCC regulatory development that affects your bank’s strategy and operations.
