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Financial Services Law Insights and Observations

OCC releases bank supervision operating plan for FY 2023

Bank Regulatory Federal Issues OCC Supervision Digital Assets Fintech Privacy, Cyber Risk & Data Security UDAP UDAAP Bank Secrecy Act Anti-Money Laundering Climate-Related Financial Risks Fair Lending Third-Party Risk Management Risk Management

On October 6, the OCC’s Committee on Bank Supervision released its bank supervision operating plan for fiscal year 2023. The plan outlines the agency’s supervision priorities and highlights several supervisory focus areas including: (i) strategic and operational planning; (ii) operational resiliency; (iii) third-party oversight and risk management; (iv) credit risk management with a focus on new products, areas of highest growth, and portfolios representing concentrations; (v) allowances for credit losses (ACL), including instances where ACL processes use third-party modeling techniques; (vi) interest rate risk; (vii) liquidity risk management; (viii) consumer compliance management systems with a focus on how programs are disclosed in relation to UDAP and UDAAP statutes; (ix) Bank Secrecy Act/AML compliance; (x) fair lending risks; (xi) Community Reinvestment Act strategies and the potential for modernization rulemaking; (xii) new products and services in areas such as payments, fintech, and digital assets; and (xiii) climate-change risk management. The plan will be used by OCC staff to guide the development of supervisory strategies for individual national banks, federal savings associations, federal branches and agencies of foreign banking organizations, and certain identified third-party service providers subject to OCC examination.

The OCC will provide updates about these priorities in its Semiannual Risk Perspective, as InfoBytes has previously covered here.