Interpretive Letter 1190 — Petition for Rulemaking Response (10/20/2025)

In addition, in light of other current competing rulemaking priorities, implementing the Petition’s request would not be an effective use of the OCC’s resources at this time. The OCC is pursuing a robust regulatory agenda focused specifically on those items that it believes based on its supervisory experience and expertise require the agency’s immediate attention. Even if the OCC agreed with Petitioner that the benefits of the petitioned rulemaking could conceivably outweigh its costs, the agency still believes that diverting its resources from the current regulatory agenda to the petitioned rulemaking would be a poor use of those resources. In light of the foregoing, the OCC has determined not to grant the Petition for rulemaking. The OCC appreciates the Petitioner’s comments. The OCC will continue to engage with policymakers, community groups, and other stakeholders on these issues, as appropriate, in a manner consistent with the OCC’s statutory mandates. Sincerely, /s/ Adam J. Cohen Senior Deputy Comptroller and Chief Counsel