OCC Releases Updated Guidance

On Tuesday, May 23, 2017, the OCC updated its policies and procedures regarding violations of various laws and regulations, which will become effective on July 1, 2017. Updates were made to the “Bank Supervision Process,” “Community Bank Supervision,” “Federal Branches and Agencies,” and “Large Bank Supervision” booklets and other sections of the Comptroller’s Handbook and internal guidance.

 

The OCC’s updated guidance highlights the principles important in implementing the agency’s mission of ensuring safe and sound bank operations. Here are the goals and practices the agency is implementing:

 

  • Ensure consistency of the purpose, processes, and procedures within and across all OCC lines of business, including community, midsize, and large banks; federal branches and agencies; and banks overseen by the OCC’s Special Supervision group.
  • Communicate violations using a consistent format:
    • Legal citation and description;
    • Summary of relevant statutory or regulatory requirements;
    • Facts supporting the violation and root cause(s);
    • Corrective action(s) required; and
    • Board and management’s commitment(s) to corrective action.
  • Reinforce the importance of timely and thorough follow-up and tracking of bank management’s corrective actions and milestones to those actions.
  • Convey the relationship of violations to matters requiring attention, CAMELS/ITCC or ROCA ratings, and the bank’s risk appetite and profile.

Emphasize the need for examiners to communicate effectively and in a timely manner with the bank’s board of directors, the bank’s management team, and OCC supervisors.