On September 25, 2018, the Office of the Comptroller of the Currency (“OCC”) released its bank supervision operating plan for fiscal year (“FY”) 2019, which begins October 1, 2018, and ends September 30, 2019. Developed by the OCC’s Committee on Bank Supervision (“CBS”) to align with “The OCC’s Strategic Plan, Fiscal Years 2019-2023” and the National Risk Committee’s risk priorities, the operating plan provides guidance on supervisory strategies for national banks, federal savings associations, federal branches, federal agencies, and technology service providers. The operating plan serves as roadmap to guide OCC staff in the identification of supervisory priorities, planning, and resource allocations for FY 2019.
CBS has four operating units: (i) the Office of the Chief National Bank Examiner; (ii) Compliance and Community Affairs; (iii) Large Bank Supervision; and (iv) Midsize and Community Bank Supervision. The operating plan sets forth supervisory priorities for each operating unit. OCC staff will use the plan to develop individual operating unit plans and risk-focused bank supervisory strategies for FY 2019, considering the different supervisory objectives necessitated by bank size, complexity, and risk profile.
The operating plan directs that supervisory strategies focus on the following risk areas:
- Cybersecurity and operational resiliency, with emphasis on maintaining information technology systems and remediating identified concerns;
- Commercial and retail credit loan underwriting, concentration risk management, credit risk management, and the allowance for loan and lease losses, including preparations for the current expected credit losses accounting rule;
- Bank Secrecy Act/anti-money laundering (BSA/AML) compliance, with emphasis on determining whether AML compliance programs keep pace with changing risk environments and regulatory developments;
- Consumer-compliance related change management process, with emphasis on implementation of regulatory requirements, including the Home Mortgage Disclosure Act, the integrated mortgage disclosure requirements under the Truth in Lending Act and Real Estate Settlement Procedures Act, and the Military Lending Act; and
- Internal controls and end-to-end processes necessary for product and service delivery, including new and revised products or strategic partnerships.
Any updates to these supervisory priorities will appear in the OCC’s Semiannual Risk Perspective.