The Office of the Comptroller of the Currency (OCC) released its bank supervision operating plan for fiscal year 2016 on September 25th. The operating plan sets forth the agency’s supervision priorities and objectives as related to national banks and federal savings associations. Large and midsize financial institutions, however, will be subject to individually approved supervisory strategies that focus on key risk areas such as compliance with new and existing regulations, credit underwriting, fair access to credit, Bank Secrecy Act, and cyber threats. Of particular interest will be the supervision and implementation of new requirements for integrated mortgage disclosures under the Truth in Lending Act (TILA) and the Real Estate Settlement Procedures Act (RESPA). Lenders and financial institutions remain somewhat in the dark as to the specific enforcement they can expect as to the new TILA/RESPA integrated disclosure rules (TRID).
In its operating plan, the OCC also notes that initiatives for fiscal year 2016 for the Office of the Chief National Bank Examiner include examining emerging risks and providing timely policy guidance, enhancing analytical tools to measure and monitor bank performance and compliance with new regulatory requirements, as well as conducting outreach sessions with the industry to present OCC perspectives on emerging issues.
Of course, we can expect updates regarding the OCC’s supervisory priorities as the OCC is expected to publish its Semiannual Risk Perspective in the spring and fall.
