Arcsalus Perspectives Emerging perspectives on risk, compliance, strategy, and AI in financial services

CRA Reform, Take Three: What the 2026 FDIC and OCC Proposal Means for Your Bank

September 2026

If you’ve been following the ongoing saga of Community Reinvestment Act (CRA) reform, you have likely already read the latest proposal. Our read is that it is a genuine step toward relief for smaller institutions. It’s been more than a year since the Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), and Federal Reserve Bank (FRB) jointly proposed to rescind the complicated and contested 2023 Final Rule, and the latest proposal, debuted in a press release on July 31, 2026 and published in the Federal Register on August 12, is the next official glimpse into the future of the CRA. As one of the goals of reform has always been consistency, and the Federal Reserve did not join the FDIC and OCC in this issuance, it’s best to consider this the first glimpse of the next iteration. All of the regulators (including the Federal Reserve) will be carefully monitoring stakeholder reaction as they move forward.

Mapping the New Bank-Fintech Reality

August 2026

Over the past two years, bank-fintech partnerships have moved from being viewed primarily as an innovation opportunity to becoming one of the most closely scrutinized areas of financial services supervision.

CAMELS Revisited

August 2026

The FFIEC’s May 19, 2026 Notice of Proposed Rulemaking to revise the Uniform Financial Institutions Rating System (CAMELS/UFIRS) represents a significant supervisory ratings recalibration, the first in nearly three decades. The proposal seeks to anchor supervisory ratings more tightly to observable financial condition and material financial risk, narrow the role of subjective management assessments, and increase transparency around component and composite ratings. These changes could reshape examiner and bank supervisory interactions, and how boards and management prioritize risk measurement and reporting.

Enterprise Stress Testing: The Case for Community Financial Institutions

June 2026

Community and regional financial institutions across the United States are navigating a risk environment characterized by persistent inflationary pressures, elevated interest rates, asset valuation stress, deposit sensitivity, funding cost competition, and mounting geopolitical and macroeconomic uncertainty. Against this backdrop, enterprise stress testing (EST) has emerged as an indispensable management discipline, one that enables leadership to anticipate adverse outcomes, evaluate capital and liquidity resilience, and make informed strategic decisions in advance or in conjunction with deteriorating market conditions.

Artificial Intelligence and Machine Learning in Asset Liability Management

June 2026

On April 17, 2026, the Federal Reserve, the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) jointly issued revised supervisory guidance on model risk management (SR 26-2) superseding SR 11-7. SR 26-2 arrives at a pivotal moment for asset liability management practitioners. The 2022–2023 rate tightening cycle exposed consequential weaknesses in deposit behavioral assumptions across the industry. The bank failures of 2023 demonstrated in real time the systemic cost of underestimating deposit repricing speed and migration risk. And simultaneous with these developments, artificial intelligence (AI) and machine learning (ML) methods are gaining meaningful consideration with respect to IRR and balance sheet management frameworks.

Model Risk Management in Transition

June 2026

On April 17, 2026, the Federal Reserve, FDIC, and OCC jointly issued revised interagency guidance on model risk management (SR 26-2), superseding the foundational SR 11-7 framework that had governed banking institutions’ model practices since 2011. The revision reflects fifteen years of evolution in how financial institutions develop and deploy quantitative tools, the emergence of artificial intelligence and machine learning in core business processes, and a deliberate regulatory shift toward principles-based oversight calibrated to institutional risk profile.