OCC Risk Perspective

The OCC recently released their Spring 2020 Semiannual Risk Perspective.  While a majority of the data is as of December 31, 2019, the bulk of the comments and analysis encompasses the effects of the COVID-19 pandemic. 

As it relates to compliance, risk is increasing, and the increase is driven by COVID-19.  As banks encountered reduced operations, employees teleworking, and a rapidly changing customer service environment; they were also expected to support customers via the CARES Act, process high volumes of PPP applications quickly, and implement a variety of forbearance and deferred payment programs. 

Banks are Stronger Than They Have Ever Been

The good news is that prior to this economic downturn, banks were the strongest they’ve been for some time. Matters requiring attention (MRA) and banks rated 4 and 5 were at 10-year lows.  This allowed banks to be a source of strength for their customers. 

The Risk Perspective highlighted the Bank Secrecy Act (BSA), and specifically addressed criminals adapting scams and money laundering techniques to exploit vulnerabilities created by the pandemic.  We addressed this in more depth in our blog.  It also addressed the transition away from the London InterBank Offered Rate (LIBOR) which we will tackle in our August 2020 Magazine.

Clarifying BSA Regulatory and Risk Management Exceptions

Finally, the OCC reiterated their previous statements clarifying BSA regulatory and risk management expectations recognizing that there may be reasonable delays in meeting compliance obligations during the pandemic.  While banks are being granted grace in terms of timeliness, it is important to note that this guidance does not remove or lessen BSA compliance expectations. 

We are Here to Help

As we’re maybe beginning to see a light at the end of the tunnel, the economy is reopening, and banking returning to a “new normal”, know that we are here to support you.  We know this has been difficult, that compliance programs have been stressed to the max, and that all of us are crossing our fingers that things were done correctly so we won’t find ourselves redoing them later.  We offer services from pre- and post-closing reviews, compliance reviews, phone and email support, etc.  We can bring you peace of mind by reviewing and identifying any concerns now so that you can fix them prior to your next exam. 


David Dickinson

David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.

He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.

David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.

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