Policy & Stakeholders

Possible changes in how institutions evaluate technology providers

Define the evidence and review process needed to evaluate a new analytical provider proportionately and responsibly.

Proposals verifiedCommercial contextFull technology brief

Federal policy items

Which federal changes matter to bank and credit union customers, what decisions may change, and what is final versus proposed.

Taking effect

Final or interim final changes already in force.

Final and effective

Community bank leverage ratio lowered to 8 percent

Published: April 29, 2026
Effective: July 1, 2026
Applies to: Qualifying community banking organizations that elect the CBLR framework

What changed

The OCC, Federal Reserve and FDIC lowered the CBLR requirement from 9 percent to 8 percent and extended, from two consecutive quarters to four, the time certain institutions can remain in the framework while not meeting all qualifying criteria, subject to the rule's limit.

Decision affected

Whether capital planning, lending growth, funding plans or CBLR election assumptions should be revisited under the new threshold.

Why it matters

The change can alter capital planning for eligible banks, but it is not blanket free capital and should not be presented as automatic lending capacity or distributable capital.

Business implications

Scenario analysis around capital, growth, funding and balance sheet tradeoffs may be relevant. Hedgehog is not claimed to have a dedicated CBLR compliance module.

What to watch

Whether a given institution qualifies for and elects the framework
Whether the institution's strategy or risk constraints dominate the ratio change

Recommended focus

Watch how the 8 percent CBLR threshold changes capital buffer, growth and funding thinking over the next four quarters.

What to watch next: The institution does not qualify, does not elect CBLR, grows out of eligibility, or has risk or strategy constraints that dominate the ratio change.

Interim final ruleAdditional context

18-month exam cycle expanded to institutions up to $6 billion

Announced: September 10, 2026
Effective: September 14, 2026
Applies to: Certain insured depository institutions up to $6 billion in assets, subject to conditions including being well managed and well capitalized

What changed

The agencies raised the asset threshold for the 18-month examination cycle from $3 billion to $6 billion for certain small insured depository institutions, with eligibility conditions including being well managed and well capitalized.

Decision affected

Mainly supervision and compliance scheduling, not core ALM or capital strategy.

Why it matters

Useful context but lower commercial priority. Less frequent exams do not reduce ongoing risk management responsibilities or automatically free material financial capacity.

Business implications

Indirect. The change may affect planning calendars, but it is secondary here to the CBLR rule and the third party risk proposals.

What to watch

Which target institutions actually qualify for the extended cycle

Recommended focus

Watch whether the longer exam cycle changes the timing of internal model, data or governance work, even when the underlying financial decisions are unchanged.

What to watch next: Evidence that qualifying institutions are materially rescheduling model, data or governance work in response.

Proposed changes

Proposals, not final rules. They do not themselves create enforceable standards.

Proposed

Proposed interagency third party risk management guidance

Published: September 15, 2026
Listed comment deadline: November 16, 2026
Applies to: Institutions supervised by the OCC, Federal Reserve, FDIC and NCUA

What changed

The agencies proposed guidance emphasizing third party risk management tailored to risk. Official materials listed November 16, 2026 as the comment deadline when checked November 5. The proposal does not itself create enforceable standards.

Decision affected

What evidence, diligence and governance are appropriate when evaluating analytics and technology vendors.

Why it matters

Relevant to vendor onboarding and procurement friction, but institutions are not required to change processes because the guidance is proposed.

Business implications

Vendor evaluation may become a larger part of technology buying conversations, raising the value of clear traceability, model governance and data handling evidence during procurement. No claim of compliance, regulator endorsement or vendor-outage modeling is made.

Commercial relevance

Positioning opportunity: If the proposal advances, vendor evaluation processes may become a more important part of technology buying conversations, favoring providers that arrive with clear evaluation evidence.

What to watch

Whether the proposal changes before finalization
Whether the listed deadline moves
Whether actual customer friction relates to the proposal at all

Recommended focus

Watch for friction in due diligence, contracting, model review and data access requirements during bank evaluations.

What to watch next: The proposal changes, the deadline moves, or actual customer friction turns out to be unrelated to the proposal.

ProposedAdditional context

Proposed companion guide for traditional community banking organizations

Listed comment deadline: November 16, 2026
Applies to: Traditional community banking organizations supervised by the Federal Reserve

What changed

A separate Federal Reserve proposed guide for traditional community banking organizations, also listing November 16, 2026 as the comment deadline as of the November 5 research check. It is separate from OP-1881 and narrower in scope.

Decision affected

How smaller and traditional community banks may interpret proportionate vendor oversight.

Why it matters

A companion document, not identical to OP-1881. Its proportionate framing matters most where the evaluating institution is a smaller community bank.

Business implications

Sales and onboarding messaging for smaller institutions may need to be segmented, with a simpler evidence package where proportionate oversight applies.

What to watch

Whether the guide is finalized in its proposed form
How community bank evaluators actually interpret proportionality

Recommended focus

Watch whether a simpler, risk proportionate evidence package reduces friction for community bank evaluations.

What to watch next: The guide changes, is withdrawn, or community bank evaluators show no distinct friction pattern.

Legislation watch

Pending bills. Introduction and advocacy are not evidence that enactment is likely.

Pending legislation

Credit union lending reform bills

Checked: November 5, 2026
Applies to: Credit unions, if enacted

What changed

Two pairs of bills are pending in Congress: the Veterans Member Business Loan Act (H.R. 507 / S. 110) and the Expanding Access to Lending Options Act (H.R. 4167 / S. 3616). Recent advocacy called for inclusion in end of year or defense legislation, but advocacy is not proof that enactment is likely.

Decision affected

If enacted: member business loan capacity, loan maturities, asset duration, funding needs and interest-rate assumptions.

Why it matters

Potentially material to affected credit unions, but the legislative path remains unresolved. Treated as a watch item, not a planning assumption.

Business implications

Scenario analysis could help affected institutions understand the impact of longer maturity or expanded lending books if the legislation advances.

What to watch

Whether either bill sees committee or floor action
Whether either is included in a moving legislative vehicle

Recommended focus

If lending authority expands, watch which part of the balance sheet institutions re-test first.

What to watch next: Committee or floor action, inclusion in a moving legislative vehicle, enactment, or meaningful bipartisan movement beyond introduction and advocacy.

Pending legislationAdditional context

Central Liquidity Facility enhancements legislation

Checked: November 5, 2026
Applies to: Credit unions using or considering Central Liquidity Facility access, if enacted

What changed

S. 3575, the NCUA Central Liquidity Facility Enhancements Act sponsored by Senators Padilla and Cramer, is pending in Congress.

Decision affected

If enacted: emergency liquidity assumptions and participation structure for affected credit unions.

Why it matters

Narrower relevance, especially for institutions actually using or considering CLF access. Secondary to the credit union lending reform bills.

Business implications

Contingency funding scenario analysis could be relevant for institutions that would change CLF participation if the bill advances.

What to watch

Whether the bill advances
Which target institutions use or are considering CLF access

Recommended focus

Watch whether a change in CLF access would materially alter contingency funding assumptions, or whether another liquidity source remains more important.

What to watch next: Committee or floor action, inclusion in a moving legislative vehicle, or enactment.

Two proposals, one listed deadline, different scope

Both are proposed and not final.

OP-1881Proposed, not final

Proposed Third-Party Risk Management Guidance

Interagency proposed guidance on third party risk management, describing practices tailored to risk.

Agencies: OCC, Federal Reserve, FDIC, NCUA
Listed comment deadline: November 16, 2026

Official page

OP-1880Proposed, not final

Proposed Third-Party Risk Management Guide for Traditional Community Banking Organizations

Federal Reserve proposed guide for traditional community banking organizations. Narrower companion scope.

Agencies: Federal Reserve
Listed comment deadline: November 16, 2026

Official page

Decision path

A typical path from policy change to institutional action. Not a universal bank workflow; actual authority varies by institution.

Decision paths

Capital, funding & rate risk

Monitor actual outcomes after a portfolio change and decide whether assumptions need updating.

1.Congress / statutory framework
2.Prudential regulators
3.Supervision / examination
4.Institution finance / treasury / ALCO
5.Assumption review / next decision

Business implications: Comparing expected results with actual results may inform the next capital or funding decision.

Detailed brief Open stakeholder map

Credit Union Merger

Reconcile assumptions for the combined balance sheet before and during integration.

1.Credit unions propose combination
2.Applicable regulatory review
3.Approval and eligible member vote
4.Legal combination
5.Operational integration

Business implications: Traceable assumptions may help reconcile the combined plan.

Detailed brief Open stakeholder map

Third party / vendor management

Define the evidence and review process needed to evaluate a new analytical provider proportionately and responsibly.

1.Agencies publish separate proposals
2.Comment process
3.Potential agency action
4.Supervisory implementation
5.Institution vendor evaluation

Business implications: Traceability and data ownership may support a factual vendor evidence package.

Detailed brief Open stakeholder map

How institutions evaluate a provider

Typical functions involved. Actual authority varies by institution.

1
Finance / treasury
Defines the decision and the analytical need.
2
Model risk or analytical governance
Reviews assumptions and model use.
3
IT / security
Reviews access, data handling and security.
4
Vendor risk / procurement
Reviews provider evidence and contract terms.
5
Accountable leadership
Authorizes spend.

Policy path

Agencies identified on the docket pages. Named officeholders are not listed.

OCC
OP-1881
Federal Reserve
OP-1881 and OP-1880
FDIC
OP-1881
NCUA
OP-1881

Engagement options

No policy position is presupposed.

Document a specific, recurring customer obstacle.
Map it to the relevant proposal text.
Confirm the product facts with Hedgehog.
Decide whether a factual comment, an association conversation or neither is warranted.

Affected institutions

Four principal institution classes are tied to the proposed interagency guidance. Scope and process differ by agency; not every institution follows the same process.

OCC-supervised institutions

National banks, federal savings associations and federal branches and agencies supervised by the OCC.

Federal Reserve-supervised banking organizations

Bank holding companies, state member banks and other organizations supervised by the Federal Reserve.

FDIC-supervised institutions

State nonmember and other insured institutions within the FDIC's applicable jurisdiction.

NCUA-supervised credit unions

Federal credit unions and, where applicable, federally insured state chartered credit unions.

Live examples elsewhere in this workspace

Existing institution and case content in this workspace. These are public events, not inferred demand.

Cases & activity

Real public transactions and dockets showing the current regulated environment in action. These are examples of current regulated activity, not evidence of Hedgehog demand.

Approved March 11, 2026

FirstSun Capital Bancorp → First Foundation Inc.

The Federal Reserve approved Denver-based FirstSun Capital Bancorp to merge with First Foundation Inc. and indirectly acquire First Foundation Bank.

Approved March 5, 2026

High Plains Bank → First National Bank of Hugo

The Federal Reserve approved High Plains Bank of Flagler, Colorado to merge with First National Bank of Hugo and establish the acquired branches.

Active docket

Current credit union merger votes

The NCUA's proposed-merger comment page lists active credit union merger votes, including SAFE Credit Union into Boeing Employees' Credit Union with a member vote listed for October 27, 2026, alongside other late 2026 votes.

A listed vote is not an approval or a completed merger.

Stakeholders & authority

See who writes the rules, who oversees implementation, and where customer decisions sit in the system.

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Policy watch

Proposals, deadlines and supervisory signals worth monitoring next. Statuses are exact: proposed, interim final, informational or final.

Proposed, not final

Proposed Third-Party Risk Management Guidance

Comments are listed as due November 16, 2026. The proposal does not itself create enforceable standards.

Interim final rule, published September 10, 2026

Expanded Examination Cycle Eligibility

Qualifying well managed, well capitalized institutions under $6 billion can be eligible for an 18-month examination cycle. Eligibility is conditional.

Supervisory update, September 21, 2026

OCC Cybersecurity Supervision Work Program update

The update added no new procedures and does not establish new regulatory expectations.

Informational, October 23, 2026

OCC Fall 2026 Interest Rate Risk Statistics Report

Aggregate interest rate risk statistics. Informational only; not OCC-suggested limits and not a new required shock test.

Final rule, effective January 18, 2027

OCC GENIUS Act final rule

Applies only to entities within the rule's stated stablecoin jurisdiction. Not relevant to institutions outside that scope.

Additional context

Source backed background. Not connected to the proposals above.

What to watch next

Watch for friction in due diligence, contracting, model review and data access requirements when institutions evaluate a provider.
Watch what evidence would make an institution's evaluation clearer without weakening its controls.

Reassessment trigger: If friction comes from product readiness, an unrelated contract issue or a requirement outside the proposal's scope, address that issue rather than treating it as an advocacy opportunity.