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Financial Services Law Insights and Observations

OCC Releases Risk Appetite Statement

OCC Risk Management

Consumer Finance

On April 12, the OCC released its Risk Appetite Statement (Statement) summarizing the agency’s largely conservative approach toward managing risks to the OCC’s mission, the financial system, and consumers. The Statement sets forth the OCC’s risk management principles and risk tolerance levels – low, medium, or high – pertaining to the following interrelated categories: (i) supervision; (ii) human capital; (iii) strategic; (iv) reputation; (v) technology; (vi) operational; (vii) legal; (viii) external; and (ix) financial. Significantly, the Statement notes that the OCC maintains a “low [risk] appetite for supervisory processes that do not ensure bank management soundly manages risk, provides fair access to financial services, treats consumers fairly, and complies with applicable laws and regulations.” By contrast, according to the Statement, the OCC has a moderate risk appetite with respect to allowing its staff to exercise flexibility in supervisory judgment, supervisory plan execution, and inter- and intra-agency collaboration, in an effort to “remain nimble in meeting the challenges of an evolving banking landscape.”