On February 10, 2025, Rodney E. Hood, the former Chairman of the National Credit Union Administration (“NCUA”), assumed the role of First Deputy Comptroller at the Office of the Comptroller of the Currency (the “OCC”). By operation of law, Mr. Hood thereby succeeded Michael J. Hsu as Acting Comptroller of the Currency under 12 U.S.C. § 4, which grants the First Deputy Comptroller the full authority of a Senate-confirmed Comptroller whenever the position is vacant. Although President Trump nominated Jonathan Gould, a current partner at Jones Day and former chief legal officer at blockchain firm Bitfury, to serve as Comptroller, Mr. Hood now leads the OCC in an acting capacity. Mr. Hood brings extensive experience to the role, having previously served on the NCUA Board of Directors, the U.S. Treasury’s Financial Stability Oversight Council and as Vice Chairman of the Federal Financial Institutions Examination Council.
In announcing Mr. Hood’s appointment on February 7, 2025, U.S. Treasury Secretary Scott Bessent emphasized that Mr. Hood’s strong leadership and career experience would “strengthen the OCC’s efforts to ensure the safety and soundness of the banking system while also enhancing economic growth.” Many public officials have echoed Secretary Bessent’s sentiments, including Senate Banking Committee Chairman Tim Scott, who praised Mr. Hood for his commitment to expanding access to financial services and improving financial inclusion.
As was suggested above, Mr. Hood’s tenure as Acting Comptroller appears destined to be brief. On February 11, 2025, the U.S. Senate received Mr. Gould’s nomination, and he is widely expected to secure confirmation in the coming weeks. In addition to his private sector experience, Mr. Gould previously worked at the OCC as Senior Deputy Comptroller and Chief Counsel from 2018 to 2021 and as Chief Counsel to the U.S. Senate Committee on Banking, Housing, and Urban Affairs before that.
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