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Financial Services Law Insights and Observations

OCC warns of key banking risks

Federal Issues OCC Covid-19 Compliance Risk Management Fintech

Federal Issues

On November 9, the OCC released its Semiannual Risk Perspective for Fall 2020, which reports on key risk areas that pose a threat to the safety and soundness of national banks and federal savings associations. In particular, the OCC noted the financial impacts of the Covid-19 pandemic on the federal banking industry, emphasizing that while economic activity rebounded in the third quarter, there is significant ongoing risk. The report discusses, as a special topic in emerging risks, growing trends in payment products and services. The report also highlights several key risk areas for banks: credit, strategic, operational, and compliance. Specifically, the report notes that credit risk is increasing as government assistance programs expire and the economic downturn has led to elevated unemployment levels. The report further notes that strategic risks affecting profitability is an emerging issue due to low interest rates, which historically have negatively affected profitability when low for a long period of time. Moreover, the report notes elevated operational risks due to complex operating environments with cybersecurity being a key concern. The increase in large-scale telework has created unique security and internal control challenges. Lastly, the report discusses elevated compliance risks due to the expedited implementation of a number of Covid-19-related assistance programs.

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