[co-author: Amanda Yap]*
On July 10, 2025, the U.S. Senate confirmed Jonathan Gould as Comptroller of the Currency in a 50–45 vote. Gould will serve a five-year term and returns to the OCC, where he previously served as Chief Counsel and Senior Deputy Comptroller under the first Trump administration. He has served in several positions at the Senate Banking, Housing and Urban Affairs Committee, including as Chief Counsel under former Chairman Sen. Mike Crapo. He also had various positions in the private sector. Gould replaces Rodney Hood, who was Acting Comptroller.
In his confirmation hearing, Gould emphasized several high-level priorities for the agency, including:
- Tailored oversight. He called for aligning supervisory expectations with each bank’s size and business model. He also said he would shine a spotlight on “debanking.”
- Focus on financial risk. Gould stated that supervision should avoid relying on reputational factors when evaluating bank practices. He also said that if banks are to serve in their role supporting the U.S. economy, they must be allowed to engage in “prudent risk-taking.”
- Support for innovation. He expressed interest in identifying safe and sound ways for banks to engage in lawful emerging activities.
*Amanda Yap is a summer associate in the Orange County office.
Putting It Into Practice: With a permanent Comptroller now in place, we will keep an eye on how the new Comptroller enacts these priorities. Institutions considering charter applications or product innovation should watch for further updates from the OCC under Gould’s leadership.
