Credit losses, cybersecurity, anti-money laundering all top priorities for bank regulator as new fiscal year opens

Allowances for credit losses (and credit itself), cybersecurity, and Bank Secrecy Act/anti-money laundering (BSA/AML)/countering the financing of terrorism (CFT) are among the priorities outlined for supervision in 2025 in a plan released Tuesday by the national bank regulator.

According to the Office of the Comptroller of the Currency (OCC), its Bank Supervision Operating Plan for FY 2025 sets forth the agency’s supervision priorities and objectives from October to September 2025. The plan is prepared by the OCC’s Committee on Bank Supervision (CBS).

“The FY 2025 Bank Supervision Operating Plan establishes priority objectives across CBS operating units,” the OCC said. “CBS managers and staff use this plan to develop and implement individual operating unit plans and risk-focused bank supervisory strategies. While the objectives are similar for the Large Bank Supervision and Midsize and Community Bank Supervision operating units, CBS managers will differentiate bank size, complexity, and risk profile when developing individual bank supervisory strategies. CBS operating plans also include resources and support for risk-focused examinations of critical processing and other banking services provided to banks by third parties.”

More specifically, the OCC said in a release, the priorities for the new fiscal year include “heightened focus” (when applicable) on:

  • Financial
    • Credit
    • Allowance for credit losses
    • Asset and liability management
    • Capital
    • Climate-related financial risks for banks with over $100 billion in total consolidated assets
  • Operational
    • Cybersecurity
    • Enterprise change management
    • Operations
    • Third-party risks
    • Payments
  • Compliance
    • Bank Secrecy Act/anti-money laundering/countering the financing of terrorism and Office of Foreign Assets Control
    • Consumer compliance
    • Community Reinvestment Act
    • Fair lending

The agency said it will adjust its supervisory strategies during the fiscal year in response to emerging risks and supervisory priorities.

“For FY 2025, examiners will focus on the impacts of volatile economic conditions including recession possibilities, uncertainty with the future path of interest rates, and deposit stability,” the agency said in its plan. “Examiners will also consider geopolitical events that may have adverse financial, operational, and compliance implications.”

The OCC said its supervisory activities can integrate “multiple risk disciplines and include cross-disciplinary teams when feasible to help provide a more complete assessment of risks.” It said strategies should focus on risk governance and control functions and leverage banks’ audit, credit risk review, and risk management processes when the OCC has validated their reliability, including scope, timeliness, and competence.

OCC Releases Bank Supervision Operating Plan for Fiscal Year 2025

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