Research
Research and perspective for community bank leaders.
Practical writing from our senior consultants on examinations, credit risk, and regulatory change, grounded in public sources.
Articles
- CAMELS · Regulatory Advisory · Examination ReadinessTipping Points in the CAMELS Rating SystemHow a community bank slips from a 2 to a 3: what examiners weigh in each CAMELS component, the red flags we see most, and a two-exam case study.
- CAMELS · Regulatory Change · Examination ReadinessWhat the Proposed CAMELS Overhaul Means for Your Management RatingThe May 2026 CAMELS proposal would narrow when management gets a 3 or worse and drop its extra weight in the composite. It is not final; what to do until it is.
- AI Governance · Model Risk · Regulatory AdvisoryBuilding an AI Inventory at a Community BankNo rule requires an AI inventory yet, but you cannot govern what you cannot list. What regulators have said about AI in 2026 and the eight fields worth tracking.
- Operational Risk · Fraud · IT AssessmentFraud as Its Own Operational RiskThe OCC calls fraud a key driver of operational losses. Why community banks should manage it as a risk of its own, with one owner, one loss picture and its own testing.
- Loan Review · Credit Risk · Examination ReadinessModifications, Extensions and PIK: How Loan Stress HidesPrudent loan accommodations are good practice, and examiners are told not to criticize them. What examiners ask about modified loans, and how to document the answers.
- CECL & ACL · Regulatory Change · Examination ReadinessWhat Examiners Will Ask About Your ACL After the OCC's July 2026 UpdateThe OCC's Allowances for Credit Losses booklet, version 2.0, sets no new standards. Six questions any bank should be ready to answer about its allowance, whoever its regulator is.
- BSA/AML · Regulatory Change · Examination ReadinessThe OCC's Community Bank BSA Exam Procedures: What Changed and What Did NotSince February 1, 2026, OCC examiners can rely more on your independent test, carry some conclusions forward and limit transaction testing. Your BSA program obligations stay the same.
- Regulatory Change · Examination Readiness · CAMELS · CECL & ACLFour Rule Changes in 2026 and What to Do About EachTwo OCC changes already in effect and two interagency proposals still open: BSA exam procedures, the allowances booklet, CAMELS revisions, and third-party risk.
Let's Talk
Let's discuss your institution's needs.
Questions about how these issues apply to your institution? Talk with a senior consultant.
Schedule a Consultation