Wednesday, December 30, 2015

OCC Report Highlights Lingering Risks and Supervisory Priorities

Author: David Schwartz J.D. CPA

Strategic, underwriting, cybersecurity, compliance, and interest rate risks lead the Office of the Comptroller of the Currency’s (OCC) supervisory concerns in its Semiannual Risk Perspective for Fall 2015.  Released December 17, 2015, the report “addresses key issues facing banks, focusing on those that pose threats to the safety and soundness of banks and their compliance with applicable laws and regulations.”  The report notes among its conclusions that the risks associated with underwriting and cybersecurity are increasing, and while strategic, compliance, and interest rate risks remain stable, they too remain supervisory priorities for 2016.

The report examines risks facing national banks and federal savings associations based on data through June 30, 2015, presenting data in four main areas: the operating environment, bank condition, key risk issues, and regulatory actions. These regular reports from the OCC are intended as as a resources to the industry, examiners, and the public. 


According to the December 17, 2015 report, the most immediate risks to federally chartered banks and savings institutions include:

  • Many national banks and federal savings associations continue to face strategic challenges to growing revenues to meet target rates of return in a slow-growth, low interest rate environment.
  • Banks and thrifts are easing credit underwriting standards and practices, including structure, terms, pricing, collateral, guarantors, and loan controls in response to competitive pressures and growth objectives. This easing is particularly evident in high-growth loan segments, such as indirect auto, commercial and industrial, and multifamily.
  • The ongoing low interest rate environment poses additional concerns as banks reach for yield by loosening underwriting and extending asset duration trends.
  • Cyber threats, reliance on service providers, and resiliency planning remain industry concerns, particularly in light of increasing global threats.


In addition to theses risks, the OCC indicated that it will also focusing increasingly on Bank Secrecy Act and anti-money laundering issues as technologies evolve.  Supplementing and supporting its risk and supervisory assessments, the OCC’s report also contains a significant amount of information about economic trends and conditions, banking industry financial and operating statistics, and regulatory actions.