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Financial Services Law Insights and Observations

OCC Semiannual Risk Perspective Highlights Risks Facing Banking Industry

OCC

Consumer Finance

On December 20, the OCC published its Semiannual Risk Perspective for fall 2012, which provides details on risks facing the banking industry. Based on data as of June 30, 2012, the semiannual report highlights risks in (i) the operating environment, (ii) the condition and performance of the banking system, (iii) funding, liquidity, and interest rate risk, and (iv) regulatory actions. Among the many findings reported by the OCC were: (i) threats to business models from low rates, sluggish economic growth, and the historic volume of new banking regulations, remain high, (ii) underwriting standards remain under pressure as banks compete aggressively for limited, high-quality lending opportunities, (iii) credit quality improvement in bank portfolios is stabilizing, (iv) compliance and reputation risks remain high as banks struggle to maintain investments consistent with higher market and regulatory standards, and (v) Bank Secrecy Act and anti-money laundering risks also are increasing as criminals become more sophisticated.