OCC Releases Semiannual Risk Perspectives Report

Locke Lord LLP

On December 16, 2015, the Office of the Comptroller of the Currency (OCC) released its Semiannual Risk Perspectives report for the fall of 2015. The OCC’s Semiannual Risk Perspective report “addresses key issues facing banks, focusing on those that pose threats to the safety and soundness of banks and their compliance with applicable laws and regulations. This report is based on data received through June 30, 2015 and indicates supervisory concerns in the following risk categories: strategic, underwriting, cybersecurity, compliance and interest rates. Significantly, the report notes, as many in the regulatory community have over the last year, that the risks associated with cybersecurity are increasing. Also increasing are the risks associated with underwriting, which appears to directly correlate with the OCC’s 21st Annual Survey of Credit Underwriting Practices, which was released on December 9, 2015, and indicates easing in the underwriting standards within commercial and retail loan products of the banks surveyed.

The OCC’s Semiannual Risk Perspectives Report can be found at: http://www.occ.gov/publications/publications-by-type/other-publications-reports/semiannual-risk-perspective/semiannual-risk-perspective-fall-2015.pdf.

The OCC’s Annual Survey of Credit Underwriting Practices can be found at: http://occ.gov/publications/publications-by-type/survey-credit-underwriting-practices-report/pub-survey-cred-under-2015.pdf.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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