Navigating Heightened Standards: What Growing Banks Need to Know
There’s a line at $50 billion in assets. Cross it, and your world changes.
Welcome to the world of “heightened standards.”
This isn’t just another layer of red tape. It’s a new operating reality. And banks hovering near that threshold—many of whom have flown under the radar for years—are about to get audited, scrutinized, and stress-tested like never before.
The Office of the Comptroller of the Currency (OCC) doesn’t deal in hypotheticals. When your assets cross that line, you’re expected to meet a higher bar in everything from cybersecurity to data governance to business continuity. No room for “we’ll get to it.” No tolerance for “we’re working on it.”
What’s Changing, and Why It Matters
At $50B, you’re no longer small enough to be ignored. You’re big enough to be a systemic risk. Which means the regulators are watching.
OCC audits shift from occasional to annual. Documentation standards rise. Your data lifecycle, from creation to destruction, must be traceable. Your risk controls? Auditable. Your governance framework? Formalized. And your internal teams? Often not ready.
Many banks are surprised they haven’t been fined already. And some know it’s only a matter of time.
The Common Pitfalls
- No clear data lifecycle management.
You can’t trace your data from origin to archive? That’s a red flag. - Lack of formal governance structure.
No data governance committee. No defined data owners. No roles, no accountability. - Fragmented ownership.
Data often falls into IT by default. But IT isn’t built for governance. And operational risk isn’t either. - Understaffed and overworked.
Many banks reaching the $50B line have zero full-time employees dedicated to data governance. They’re trying to hire—after the audit has already started. - Overreliance on outdated policies.
A ten-year-old policy sitting in a dusty SharePoint folder doesn’t count. Regulators want proof of implementation, not intention.
The Compliance Crunch
Here’s how it plays out: The OCC shows up. They audit. You get a “Matter Requiring Attention” (MRA). Sometimes even a “Matter Requiring Immediate Attention” (MRIA). That’s not just paperwork—it’s a clock starting. You typically have 30 to 60 days to respond. If you’re not ready, that’s where the trouble—and potential fines—begin.
Fines are one thing. Reputational damage is another.
Your customers don’t care what the OCC found. They care that you weren’t prepared.
So What Do You Do?
You don’t wait until the audit. You get ahead of it.
That means:
- Building a proactive data governance framework.
- Defining data ownership and accountability.
- Mapping your data lifecycle.
- Tightening third-party risk controls.
- Aligning with frameworks like NIST CSF.
This isn’t about fixing a single issue. It’s about creating a system that can stand up to sustained scrutiny.
Why Proactive Governance Wins
When done right, governance isn’t just a compliance function. It’s a performance advantage.
It streamlines operations. Reduces risk. And opens the door to smarter data use—fueling everything from AI models to customer personalization.
In contrast, reactive governance means scrambling. Wasting time. And often paying more to clean up preventable messes.
What the Best Banks Are Doing
Forward-looking banks aren’t waiting for a knock from the OCC. They’re conducting pre-audit health checks. Engaging experts. Building programs that work—then documenting them.
They’re not just hiring a Chief Data Officer. They’re giving that person authority and budget. They’re creating Data Governance Committees. They’re embedding data quality and lifecycle tracking into their systems.
In short, they’re treating data governance not as a checkbox—but as infrastructure.
The Managed Service Advantage
Even with a plan, most expanding banks don’t have the in-house resources to execute it. That’s why many are turning to outside partners to build and run their governance programs. Not just for compliance remediation—but as a long-term managed service.
Why? Because regulatory pressure is constant. Audits are recurring. And internal teams can’t keep up.
A strong managed services partner brings proven frameworks, faster execution, and a deeper bench of experts. For banks, it’s the difference between scrambling and scaling.
The Bottom Line
If your bank is closing in on $50B in assets, heightened standards aren’t a future issue. They’re here.
This is the moment to act—not react.
Build your data governance foundation now. Implement lifecycle tracking. Establish formal ownership. Tighten your risk posture. And bring in partners who’ve done this before.
Because compliance is no longer optional. And getting ready after the fact is too late.
Your future depends on how you manage your data today.
Want help getting started? Consider a light-touch health check to assess your readiness before the OCC does it for you. You might be more exposed than you think.
