The Office of the Comptroller of the Currency (OCC) has released the August 2026 update to its Bank Accounting Advisory Series (BAAS), an annual resource that helps banks, examiners, and industry professionals navigate complex accounting and regulatory reporting issues.
While the BAAS is not a formal rule or regulation, it serves as an important source of interpretive guidance from the OCC’s Office of the Chief Accountant (OCA). For many institutions, it provides valuable insight into how accounting standards are applied in practice and how regulators may view specific reporting issues.
What’s New in the 2026 Update?
This year’s edition introduces three new questions covering topics that continue to generate interest across the industry:
- Subtopic 2B, Nonaccrual Loans, Question 45
- Subtopic 11E, Grants Received by Banks, Question 3
- Subtopic 12C, Acquired Loans, Question 10
The OCC also updated several existing entries, including guidance related to:
- Miscellaneous Other Assets (Subtopic 5C, Question 2)
- Acquisitions (Subtopic 10A, Question 1)
- Grants Received by Banks (Subtopic 11E, Question 1)
- Acquired Loans (Subtopic 12C, Questions 1, 4, 5, 6, and 7)
In addition, the OCC made various editorial updates and renumbered certain entries as part of its annual review process. Importantly, these administrative changes do not alter the agency’s existing conclusions or interpretations.
A Continued Focus on Lending & Credit Issues
One trend that stands out in this year’s release is the continued attention given to acquired loans and loan accounting topics.
With multiple updates within Subtopic 12C and a new question added to that section, the OCC is signaling that acquired loan accounting remains an area where institutions continue to seek clarification. Whether driven by merger activity, balance sheet growth strategies, or evolving credit portfolios, these topics remain highly relevant for banks evaluating acquisition-related accounting and reporting considerations.
Similarly, the addition of a new question on nonaccrual loans reflects the ongoing importance of credit quality monitoring and consistent application of loan accounting guidance in today’s environment.
Review the Full Update
Banks should consider reviewing the August 2026 BAAS update to identify any changes that could affect accounting policies, regulatory reporting, loan accounting practices, or transaction-specific analyses.
Download the full August 2026 Bank Accounting Advisory Series HERE.
If you have questions about how the updated guidance may impact your institution, or would like assistance evaluating specific accounting or regulatory reporting considerations, we are here to help. Please do not hesitate to reach out to discuss the changes and help assess the potential implications for your organization.
This material has been prepared for general, informational purposes only and is not intended to provide, and should not be relied on for, tax, legal or accounting advice. Should you require any such advice, please contact us directly. The information contained herein does not create, and your review or use of the information does not constitute, an accountant-client relationship.
