The OCC has released its 2023 Bank Supervision Operating Plan, which outlines its priorities. Even if you’re not regulated by the OCC, we would expect the focus of other Agencies to be somewhat similar. Here’s a look at some of the OCC’s areas of focus:
Consumer Compliance: Examiners are to focus on compliance management systems, which the Plan specifies includes complaint management and the development of new or “innovative” products, services and/or delivery channels. Specific focus should be given to how programs are implemented and disclosed, considering UDAAP prohibitions. Examiners will also be assessing the adequacy of compliance resources, including training, the number and expertise of compliance staff, any changes in staff/structures and the use of third parties.
Bank Secrecy Act: It’s no surprise that focus will be placed on risk management and will consider an institution’s products/services, customer base and areas served. If you’re involved with BSA compliance in your institution, you know that hardly a day goes by without some type of OFAC news, and accordingly, focus will be placed on OFAC oversight. Expect continued focus in this area as well as on change management related to the Anti-Money Laundering Act of 2020 and, of course, suspicious activity monitoring and reporting.
Fair Lending: Again, expect examiners to assess fair lending risks, specifically when it comes to fair access to products and services. Make sure you’ve assessed your redlining risks and looked to mitigate them. Expect examiners to look at the entire life cycle of your products and to look closely for any bias in appraisals or property valuations.
There’s nothing too surprising here, but if you have an exam coming up in the next year, you can expect these areas to be addressed, especially if you’re OCC-regulated.
Published
2022/10/13
