OCC Supervision Priorities for 2021

The OCC has released its bank supervision operating plan for the 2021 fiscal year. The OCC plans for supervision efforts to be flexible, recognizing the broad and specific impacts of the pandemic and resulting economic, financial, operation, and compliance implications.

Not surprisingly, the OCC stated many supervision efforts will focus on the pandemic. Specific points noted include:

  • Credit risk management, due to likely weaker economic conditions;
  • Residential and commercial real estate concentration risk management- particularly in sectors that were most affected by COVID-19;
  • Compliance risk management tied to pandemic- related activities such as CARES Act loan forbearance requirements or other consumer loan or account accommodations;
  • Fair lending exams and risk assessments, including those associated with pandemic-related loan accommodations and loss mitigation efforts.

Additional priorities touched on cybersecurity, CRA performance associated with new rules, BSA/AML compliance, impact of low-rate environment, and more. For the full list, see the OCC press release. Let ABS help make sure you are meeting these priorities. Contact us now!

OCC Proposes Rule Regarding the CRA General Performance Standards

As a follow-up to the final rule published in June, the OCC has now released a proposed approach to determine the CRA evaluation measure benchmarks, retail lending distribution test thresholds, and community development minimums. The proposal also explains how the OCC would assess significant declines in CRA activities levels in connection with performance context following the initial establishment of the benchmarks, minimums, and thresholds. Finally, the proposed rule would make clarifying and technical amendments to the 2020 final rule. Comments are now being accepted.