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Financial Services Law Insights and Observations

OCC releases FY 2025 bank supervision operating plan

Bank Regulatory OCC Bank Supervision

On October 1, the OCC released its bank supervision operating plan for fiscal year (FY) 2025. The OCC outlined its supervision priorities and objectives which will guide the implementation of supervisory strategies for national banks, federal savings associations, federal branches and agencies of foreign banking organizations, and third-party service providers subject to OCC examination. As described by the OCC, the plan will help set supervisory priorities, planning, and resource allocation.

Key areas of focus for FY 2025 include:

  • Financial: Credit, allowance for credit losses, asset and liability management, capital, and climate-related financial risks for banks with over $100 billion in total consolidated assets.
  • Operational: Cybersecurity, enterprise change management, third-party risks, and payments.
  • Compliance: BSA/AML/countering the financing of terrorism and OFAC compliance, consumer compliance, CRA, and fair lending.

The OCC will provide periodic updates on supervisory priorities, emerging risks, and horizontal risk assessments in its Semiannual Risk Perspective reports, released in the fall and spring.