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Financial Services Law Insights and Observations

OCC Releases Semiannual Risk Perspective Report

OCC Anti-Money Laundering Bank Secrecy Act Risk Management Privacy/Cyber Risk & Data Security

Consumer Finance

On December 16, the OCC released its Semiannual Risk Perspective report to provide an overview of supervisory concerns for the federal banking system, including operational and compliance risks. According to the report, which covers data through June 30, 2015, risks relating to strategic, compliance, and interest rates remain unchanged, but risks connected to underwriting and cybersecurity continue to grow. Notable findings in the report reveal that (i) the low interest rate environment has led banks to reevaluate risk tolerance and extend their reach for yield; and (ii) banks are responding to competitive pressures and growth objectives by adopting a more relaxed approach toward credit underwriting standards and practices, particularly in high-growth loan segments, such as indirect auto, commercial and industrial, and multifamily.

The report emphasizes cyber threats and Bank Secrecy Act (BSA) and anti-money laundering (ALM) risks as growing concerns, commenting that “[c]yber attacks against cybersecurity products and services further increase risk to banks because of the release or sale of malware and zero-day vulnerabilities,” and “BSA/AML risks remain high, as technological developments that benefit customers through enhanced products and greater access to financial services may be vulnerable to criminals who exploit such innovations.”