Financial · guide
OCC Bulletins, FDIC FILs and Fed SR Letters: What Each Is and Who Must Act
Updated
Three regulators, three document series
Federally supervised banks answer to one of three primary federal supervisors, and each one communicates through its own numbered series. OCC bulletins go to national banks, federal savings associations, and federal branches and agencies of foreign banks. FDIC Financial Institution Letters go to FDIC-supervised institutions, which are mostly state-chartered banks and savings associations that are not Federal Reserve members. Federal Reserve SR letters go to banking organizations supervised by the Federal Reserve, including state member banks and holding companies. The first skill is reading the number; the second is reading the applicability line.
OCC bulletins
An OCC bulletin is the OCC's formal channel for issuing guidance, announcing proposed and final rules, transmitting interagency statements and rescinding old documents. Bulletins are numbered OCC YYYY-NN in order of issuance: OCC 2026-2 (February 17, 2026) announced a proposed rule on the bank appeals process, and OCC 2026-12 (April 7, 2026) transmitted a final rule (OCC 2026 Bulletins). Each bulletin opens with an addressee line, typically "Chief Executive Officers of All National Banks, Federal Savings Associations, and Federal Branches and Agencies," followed by a "Note for Community Banks" that says in a sentence whether the document applies to community institutions, and a "Highlights" list (OCC Bulletin 2023-17). Read those two lines before anything else.
FDIC Financial Institution Letters
FDIC Financial Institution Letters, or FILs, "are addressed to the Chief Executive Officers of the financial institutions on the FIL's distribution list -- generally, FDIC-supervised institutions." They announce new regulations and policies, new FDIC publications and other matters of interest to bank management (FDIC Financial Institution Letters). FILs are numbered FIL-NN-YYYY, sequence first and year second, which is the reverse of the OCC pattern. FIL-29-2023, for example, transmitted the June 2023 interagency guidance on third-party risk management (FIL-29-2023).
Federal Reserve SR letters and CA letters
Supervision and Regulation letters, known as SR letters, "address significant policy and procedural matters related to the Federal Reserve System's supervisory responsibilities." They are numbered SR YY-N; the first letter of 2005 was SR 05-1. Before November 2001 the numbers carried functional suffixes such as SUP or ENF, which explains the odd-looking citations in older material (Federal Reserve SR Letters). Each SR letter has an applicability line; SR 23-4, for example, "applies to all banking organizations supervised by the Federal Reserve" (SR 23-4).
Consumer Affairs letters, or CA letters, are the consumer-compliance counterpart. They "address significant policy and procedural matters related to the Federal Reserve System's consumer compliance supervisory responsibilities," are numbered CA YY-N on the same pattern, and are "sent to banking supervision staff at the Board and the Reserve Banks and, in some instances, to supervised banking organizations" (Federal Reserve CA Letters). A CA letter is often the first place a new consumer-compliance examination procedure appears.
Interagency guidance: one document, three numbers
When the agencies act together, the same text is issued under three cover documents on or about the same day. The June 2023 interagency guidance on third-party relationships appeared as OCC Bulletin 2023-17 (June 6, 2023), FDIC FIL-29-2023 (June 6, 2023) and Federal Reserve SR 23-4 (June 7, 2023) (OCC Bulletin 2023-17; FIL-29-2023; SR 23-4). Each cover document adds that agency's own applicability statement. When you see one, look for the other two, and read the cover from your own regulator.
Does it apply to my charter?
| Your institution | Primary federal supervisor | Cover document to read | Also watch |
|---|---|---|---|
| National bank or federal savings association | OCC | OCC bulletin (Note for Community Banks) | Interagency items via FDIC and Fed for context |
| State nonmember bank or state savings association | FDIC | FIL (distribution list line) | State regulator issuances |
| State member bank | Federal Reserve | SR letter (applicability line) and CA letters | State regulator issuances |
| Bank or savings and loan holding company | Federal Reserve | SR letter and CA letters | The subsidiary bank's own supervisor |
The applicability line answers most questions. When a document is addressed to a broader category than your charter, or is silent, treat it as context rather than an obligation until your examiner says otherwise.
Guidance is not regulation
On September 11, 2018, the OCC, Federal Reserve, FDIC, NCUA and CFPB issued an interagency statement clarifying the role of supervisory guidance, and in early 2021 each agency codified it as a rule (CFPB, Role of Supervisory Guidance). The OCC's version, transmitted by OCC Bulletin 2021-8 and effective March 15, 2021, "reaffirms that supervisory guidance, unlike statutes and regulations, does not have the force and effect of law," and states that the OCC "does not take enforcement actions on the basis of a 'violation' of, or 'non-compliance' with, supervisory guidance" (OCC Bulletin 2021-8). The Federal Reserve approved its parallel rule on March 31, 2021 (Federal Reserve press release).
In practice: a bulletin, FIL or SR letter that transmits a final rule points to binding requirements that live in the Code of Federal Regulations, while one that transmits guidance describes supervisory expectations examiners use to evaluate safety and soundness. Guidance shapes examinations and conversations with your examiner, but it cannot be the sole basis for a citation. Reading the cover document tells you which kind you are holding.
Where to subscribe
- OCC: the "OCC News" email list "delivers news, bulletins, alerts, and announcements" (Subscribe to OCC Email Updates).
- FDIC: the email subscription box on the FIL index page (FDIC Financial Institution Letters).
- Federal Reserve: the banking information RSS feed and email alerts linked from the SR letters page (Federal Reserve SR Letters).
RegPing's financial-regulation bot delivers new OCC bulletins, FDIC FILs and Federal Reserve SR letters into Discord as they are published.
Where to verify
- OCC bulletins by year
- FDIC Financial Institution Letters
- Federal Reserve SR Letters
- Federal Reserve CA Letters
- OCC Bulletin 2021-8, Role of Supervisory Guidance
- CFPB final rule, Role of Supervisory Guidance
This guide is general information, not legal advice. Verify against the primary source and consult counsel before acting.
Questions people ask
How are OCC bulletins, FDIC FILs and Fed SR letters numbered?
OCC bulletins use OCC YYYY-NN (for example OCC 2026-12). FDIC FILs use FIL-NN-YYYY (for example FIL-29-2023). Federal Reserve SR letters use SR YY-N (for example SR 23-4), and Consumer Affairs letters use CA YY-N on the same pattern.
How do I know whether an OCC bulletin or FIL applies to my bank?
Read the addressee or applicability line and, on OCC bulletins, the Note for Community Banks. Documents from your primary federal supervisor apply to you; the same interagency guidance from the other agencies is context.
Can examiners cite a bank for violating supervisory guidance?
No. Under the 2021 interagency rules codifying the 2018 statement, supervisory guidance does not have the force and effect of law and the agencies do not take enforcement actions based on non-compliance with guidance. Guidance still informs how examiners assess safety and soundness.