The Data Governance Blind Spots That Can Trigger an OCC MRA (and How to Fix Them)
“We thought we had governance covered.”
That’s the most common phrase heard right after an OCC audit… and right before a Matter Requiring Attention (MRA) lands on a compliance team’s desk.
For many banks—especially those scaling toward the $50 billion threshold—this isn’t theory. It’s reality. One that comes with increased scrutiny, aggressive audit schedules, and very little room for error.
The problem? Most banks think data governance is a checkbox. A set of policies. Maybe a SharePoint folder.
It’s not.
And what you don’t see—your blind spots—are what get you fined.
Top 5 Data Governance Issues That Lead to MRAs
These aren’t edge cases. They’re patterns. The OCC sees them again and again. So do we.
- No Data Lineage or Traceability
You can’t prove where your data came from, who touched it, or where it lives now. That’s a dealbreaker. Regulators want to see start-to-finish visibility—from ingestion to retention to destruction. - Undefined Ownership
Who owns customer records? Who’s accountable for product data? If your answer is “IT” or “everyone,” you’re exposed. The OCC expects clearly assigned data owners and stewards. - Outdated or Missing Policies
A dusty governance policy from 2012 doesn’t count. If you can’t show recent reviews, updates, and enforcement? You’re out of compliance. - Siloed Systems and Shadow Data
Data lives in too many places—uncoordinated, inconsistent, and often unknown to the governance team. Shadow systems are governance killers. - No Governance Committee or Enforcement Structure
If no one is accountable at the organizational level, nothing sticks. The OCC doesn’t want theory. They want structure. They want meeting minutes. They want action.
These blind spots often go unnoticed internally. Until an auditor shines a light on them.
Real-World Wake-Up Calls
It happens more often than you’d think.
A regional bank with growing digital capabilities—confident they were audit-ready—discovered they had no defined lifecycle for customer PII. They couldn’t prove when or how data was deleted. Result? MRA.
Another institution had a dozen policy documents. None of them were current. No one knew which ones governed what. Their data classification standard hadn’t been touched in six years. MRA.
One bank had designated “data owners,” but couldn’t explain what those people were responsible for. When asked during the audit, even the supposed owners didn’t know. MRA.
These aren’t edge failures. They’re organizational habits. And they’re preventable.
Your MRA Prevention Plan
This isn’t about fear. It’s about control. A proactive governance strategy beats a reactive remediation plan every time.
Here’s how to get in front of the problem—before the OCC forces your hand.
1. Start with a Baseline Assessment
Don’t assume. Assess.
Run a current-state review of your data governance posture:
- What policies exist?
- Who owns what?
- Where are the gaps in traceability?
- Which systems contain uncontrolled or undocumented data?
Even a lightweight assessment can surface major risks.
2. Assign Real Data Ownership
Ownership isn’t a title. It’s accountability.
Each domain—customer, product, finance, operations—should have a named data owner with clear responsibilities. And those owners need to know what’s expected.
Support them with stewards who manage the day-to-day. Provide training. Make it real.
3. Stand Up (or Reinforce) a Governance Committee
Cross-functional. Empowered. Regularly meeting. With the authority to set policy and resolve disputes.
If you don’t have one, build it now. If you do have one, ask when they last met—and what they actually did.
The committee is your governance engine. Without it, everything stalls.
4. Document and Refresh Policies
Every policy should:
- Be reviewed annually.
- Have a clear owner.
- Be easy to access, read, and enforce.
Start with the core: data classification, lifecycle management, access controls, and retention.
If you’re not confident putting your policies in front of an auditor tomorrow, they’re not ready.
5. Establish Lineage and Lifecycle Tracking
Can you follow data from entry point to storage to archive? If not, this is priority one.
Implement tools or processes to track data lineage. Know when data is changed, moved, copied, or deleted. The OCC isn’t just asking what data you have—they’re asking what happens to it.
This step alone can prevent multiple MRAs.
The Role of Outside Support
You don’t have to build all of this from scratch. And you don’t have to do it alone.
Most banks just nearing the $50B threshold don’t have the in-house capacity—or the regulatory experience—to stand up mature governance programs quickly. That’s where outside support makes all the difference.
Here’s what a strong partner brings:
- Proven governance frameworks already aligned to OCC expectations
- Accelerators for policies, training materials, committee structures, and role definitions
- Tools and templates to fast-track lineage mapping, ownership models, and lifecycle documentation
- Hands-on remediation support if you’re already in MRA territory
- Managed services to sustain governance long after the audit is over
This isn’t about checking a box. It’s about transforming governance from reactive pain point into strategic advantage.
And for banks entering heightened standards territory, that transformation isn’t optional.
Final Thoughts
An MRA isn’t just a warning. It’s a line in the sand. A signal that your bank is now in the spotlight—every audit, every policy, every system.
But here’s the thing: the audit isn’t your real problem. The blind spots are.
Governance isn’t just about compliance. It’s about clarity. Control. Confidence.
Banks that take governance seriously don’t scramble. They lead. They move faster, serve better, and sleep easier knowing their data isn’t just protected—it’s managed with intention.
If your team can’t answer basic questions about ownership, traceability, or lifecycle? You’re exposed.
Don’t wait for the OCC to tell you that.
Find the blind spots. Fix them. Build governance that actually governs.
Before someone else makes you do it.
