OCC 2021 Fiscal Year Bank Supervision Operating Plan

Practus LLPLegal Insights

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OCC Rolls Out First Fiscal Year Bank Supervision Operating Plan

A Message from Financial Services Partner, Andrea Shaw

office of comptroller of the currency OCC logo

The Office of the Comptroller of the Currency (“OCC”) recently issued their 2021 Fiscal Year Bank Supervision Operating Plan. The OCC Fiscal Year runs from October 1, 2020 and ends September 30, 2021. 

This provides banks with great insight as to what the OCC plans to focus on over the next twelve months in addition to their baseline supervision of national banks. Of course, the plan reserves the right to remain flexible and make adjustments during the year as needed, but it is a great starting point for banks to use in their own risk assessments to prioritize risk management work.

I’ve included a link to the entire publication but here are a few highlights: 

  • As you might expect given the current pandemic and economic challenges, the OCC plans to focus on various aspects of credit risk management and compliance with the CARES Act.
  • Also unique to our current environment, the OCC will also be focused on how banks are preparing for phaseout of the London Interbank Offering Rate (“LIBOR”) after 2021. If your bank doesn’t have a plan, now is the time to get one in place before your next exam!
  • A group of “familiar friends” continue to make the list, such as BSA/AML, CRA performance (but with a focus on the new guidance issued June 5, 2020).  Third party and change management oversight remain on the OCC radar, as does payment systems products and services.

Read the full article from the Office of the Comptroller of the Currency (“OCC”) here. 

Contact Andrea Shaw

attorney andrea j. shawPractus Attorney Andrea Shaw  specializes in Financial Services Law.  She has extensive knowledge in consumer finance, bank regulation, and privacy law with more than 15 years advising both state and federally chartered banks. Andrea has a deep understanding of the unique challenges clients face, and guides them through the process with clear communication and focus. As a regulator and counsel, Andrea has a passion for helping clients solve their most complex problems.  With a degree in Equine Business Management, she is also passionate about horses and enjoys practicing in equine law.

Prior to joining Practus, Andrea served as a Shareholder with Bernstein Shur and Senior Counsel to the credit card and merchant solutions team and head of legal fair lending for a top 10 bank.