The 32nd Comptroller of the Currency
Jonathan V. Gould · Chief Counsel 2018–2021 · Comptroller 2025– · Confirmed 50–45, Jul 10 2025 · Sworn in Jul 15 2025
Gould is the rare regulator running a second act in the same building. As Chief Counsel from 2018 to 2021 he wrote the legal architecture for bank crypto custody, stablecoin reserves, and the first fintech and crypto charters. As Comptroller since July 2025 he is cementing that architecture — resetting supervisory posture, defending and expanding National Bank Act preemption on two fronts, and standing up the OCC as the federal home for stablecoin issuers under the GENIUS Act. This tracker maps both tenures, with each first-term action linked to the present-day rule that now carries it.
Gould's supervisory thesis is a deliberate reset: move examination away from process and discretion toward material financial risk. The agenda runs from community-bank exam tailoring and capital relief to the elimination of reputation risk, a CAMELS overhaul, and an open challenge to post-2008 resolution-planning orthodoxy.
A signature Gould priority is defending — and proactively expanding — National Bank Act preemption, now on two fronts. The escrow-interest fight produced finalized rules and a favorable Second Circuit ruling on remand from Cantero; a newer interchange-fee front targets state laws like Illinois' IFPA, with a Seventh Circuit remand pending. His approach pairs rulemaking with amicus engagement and coalition-building.
Gould has reopened the national charter to non-traditional applicants at a pace not seen in years — approving Erebor (the first de novo national bank of his tenure), weighing a politically charged stablecoin trust application, and positioning the OCC as the federal supervisor of stablecoin issuers under the GENIUS Act. The throughline runs straight back to the charters and legal opinions he set in motion in 2020–21.
As Senior Deputy Comptroller and Chief Counsel from December 2018 to 2021 — arriving from the Senate Banking Committee, where he was chief counsel under Chairman Crapo — Gould oversaw the OCC's legal, licensing, and enforcement functions and a staff of roughly 230. Under Comptrollers Otting and (acting) Brooks, his office authored the crypto and stablecoin interpretive letters and cleared the first fintech and crypto charters. Read this tab as the blueprint: nearly every current action has a 2020–21 antecedent.
Sources. Linked entries cite OCC news releases, bulletins, and Federal Register notices, plus FSOC and FFIEC materials. Interpretive Letters 1170 / 1172 / 1174 link to OCC primary PDFs. Charter decisions (Varo, Anchorage) and the valid-when-made / true-lender rules are documented in the OCC's Interpretations & Actions archive and the Federal Register; primary links are left for the editor to slot in.
Secondary synthesis drawn from Consumer Finance Monitor, Davis Polk, King & Spalding, Orrick InfoBytes, Latham, and Sheppard Mullin. Compiled for BankRegWire · informational tracker, not legal advice.