The Office of the Comptroller of the Currency (OCC), in its new role as supervisor of federal savings associations (including federal savings banks, collectively referred to as FSAs), has rescinded much guidance that had been issued by the Office of Thrift Supervision (OTS), the former regulator of FSAs. In Bulletin 2012-15, the OCC lists the rescinded OTS documents and the OCC documents, if any, that replace the rescinded documents, in Attachment A. While the specific OCC documents now applicable to FSAs in place of the rescinded items are identified in the attached table, the OCC points out that "several [other] key Comptroller’s Handbook booklets warrant close review. These booklets—"Bank Supervision Process," "Community Bank Supervision," and "Large Bank Supervision,"—explain the foundation of the OCC’s supervisory philosophy and contain minimum examination procedures that apply to FSAs. As the OCC continues its progress toward one integrated policy platform for national banks and FSAs, it is increasingly important for FSAs to have a thorough understanding of the supervisory philosophy contained in these booklets and how the OCC organizes this guidance."

Despite rescission of many OTS initiatives, the Bulletin states that the OCC and the OTS shared many objectives. "Even before the policy integration is completed, FSAs and national banks may find guidance issued to the other charter type useful for informational purposes. For example, an FSA may find more detailed OCC guidance on a particular topic, such as commercial lending, or a national bank may find more current guidance issued by the OTS on a particular topic, such as mortgage banking. In the course of ongoing supervision the OCC may direct national banks and FSAs to consult such guidance for further information on the subject area or to address supervisory concerns.”

It is notable, however, that the Bulletin states that "OCC will not cite noncompliance with the requirements included in such guidance, however, until application of these requirements has been officially communicated and related OTS-issued guidance, if any, has been rescinded." Thus, presumably, non-compliance during the period preceding the issuance of the rescission notice will not be used against institutions.

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