Comptroller Talks Interest Rate, Compliance, and Cybersecurity Risks Facing Financial Institutions

Dodd-Frank OCC Bank Compliance Privacy/Cyber Risk & Data Security

On July 24, OCC Comptroller Curry delivered remarks before the New England Council in Boston, MA regarding the risks that financial institutions face today. Rising interest rates and regulatory compliance were two of the three risks discussed. Curry emphasized that the inevitable rise in interest rates could greatly affect loan quality, particularly loans that were not carefully underwritten to begin with, and that ”[l]oans that are typically refinanced, such as leveraged loans,” would be particularly severely affected. Recognizing the impact that Dodd-Frank continues to have on banks, Curry said that financial institutions face two categories of risk from new regulations: (i) “banks run afoul of the new regulations, possibly damaging their reputations and subjecting themselves to regulatory penalties”; and (ii) banks devote their time and money to regulatory compliance, rather than putting those resources toward serving their customers and communities. The final and “perhaps the foremost risk facing banks today,” according to Curry, is cyber threats. Curry outlined the agency’s efforts to curtail cyber intrusion in the banking industry, highlighting the June 30 release of its Semiannual Risk Assessment and the creation of a Cybersecurity and Critical Infrastructure Working Group, which was designed to (i) increase cybersecurity awareness; (ii) promote best practices; and (iii) strengthen regulatory oversight of cybersecurity readiness. Curry noted, however, that information-sharing is just as important as self-assessment and supervisory oversight: “We strongly recommend … that financial institutions of all sizes participate in the Financial Services Information Sharing and Analysis Center, a non-profit information-sharing forum established by financial services industry participants to facilitate the sharing of physical and cyber threat and vulnerability information.” Collaboration among banks of all sizes and non-bank providers, Curry stated, can be a “game-changer” in more ways than one: “By promoting the discovery of common interests and common responses to the risks that you face in your businesses and we all face together, you provide an invaluable service to New England and to the United States.”