Examiners have been asked to review charter and merger applications alongside the agency’s licensing specialists, according to people familiar with the matter cited by Bloomberg. The OCC has not had to cancel or delay examinations because of the staffing constraints, but the reassignments have made gaps in its supervisory ranks more noticeable.
The OCC has lost more than 1,000 employees since President Donald Trump took office in January 2025 through retirements, buyouts and layoffs. The agency had approximately 2,600 employees as of August, according to Office of Personnel Management data. Although the reductions did not specifically target examiners, many have retired or otherwise left the agency.
The staffing pressure comes as Comptroller of the Currency Jonathan Gould and the Trump administration prioritize approving new bank charters. The OCC received applications from at least 50 firms between the beginning of 2025 and the end of October, compared with one application in 2024 and five in 2023.
The agency has historically invited examiners and attorneys to volunteer for charter reviews, which can involve assessing applicants’ plans for cybersecurity, capital, liquidity and regulatory compliance. In previous administrations, however, enough examiners remained in place to cover employees assigned to that work.
Otuoze Baiye, a former OCC and New York Department of Financial Services examiner, told Bloomberg that the staffing changes raise concerns about the regulator’s capacity to handle both licensing and examinations. The agency continues to pursue enforcement actions, including a $750 million fine against Bank of America in October over anti-money-laundering lapses.
The chartering push also comes as the OCC faces legal challenges from community bankers over its approach to cryptocurrency firms. The Independent Community Bankers of America sued the regulator in October, arguing that the office improperly expanded its authority to grant national trust bank charters to companies that do not take deposits or primarily perform traditional fiduciary activities.
The OCC, meanwhile, maintains that its rule clarifies existing authority under the National Bank Act. The dispute adds another layer of scrutiny to the agency’s chartering decisions as it works through an unprecedented volume of applications.
