The Office of the Comptroller of the Currency’s (OCC’s) Committee on Bank Supervision has released its Fiscal Year 2016 priorities. Not surprisingly, the top supervision and examination priorities are
- governance and oversight,
- credit underwriting and risk, and
- cybersecurity.
Other priorities include the Bank Secrecy Act/money laundering, operational risk, compliance, interest rate risk, and fair access. The OCC’s expectations under each of the priorities differ for large banks and midsize and community banks. The OCC continues to emphasize compliance with its guidance on third-party relationships. OCC examiners will also begin to use the Federal Financial Institutions Examination Council’s Cybersecurity Assessment Tool released in June 2015 to supplement their exam work.. The Cybersecurity Assessment Tool has caused some concerns among smaller banks for potentially being too rigid.
These supervisory priorities are consistent with the top risks identified in the OCC’s Spring 2015 Semiannual Risk Perspective. All OCC-supervised institutions should be mindful of the 2016 priorities and be prepared for examiners to emphasize each of the categories during the next exam.