On April 10, 2018, the Federal Financial Institutions Examination Council (the “FFIEC”), an interagency body composed of the Board of Governors of the Federal Reserve System, Consumer Financial Protection Bureau, Federal Deposit Insurance Corporation, National Credit Union Administration, Office of the Comptroller of the Currency and the State Liaison Committee, issued guidance to assist financial institutions in analyzing the use of cyber insurance in an effective risk management program (the “Guidance”).
Here are our observations on the 2018 OCC Bank Supervision Operating Plan:
– Cybersecurity is a top priority.
– Credit underwriting, as always.
– BSA is frequently mentioned.
– Business model sustainability and change management are emphasizing the M in CAMELS.
– Fair lending is far down the list.
Click here for the OCC press release.