OCC’s 2025 Bank Supervision Operating Plan

On October 1, 2024, the OCC released its bank supervision operating plan for fiscal year 2025, which begins on October 1, 2024, and ends on September 30, 2025. The plan provides the foundation for policy initiatives and for supervisory strategies as applied to individual national banks, federal savings associations, federal branches, federal agencies, and technology service providers. The OCC staff will use this plan to guide their supervisory priorities, planning, and resource allocations.

As written in the operating plan, examiners will focus on the impacts of volatile economic conditions such as recession possibilities, uncertainty with the future path of interest rates, and deposit stability. They will also consider geopolitical events that may have adverse financial, operational, and compliance implications. In addition to the baseline activities, OCC risk-based supervision will heighten its focus on the following areas for 2025:

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 OCC’s new release can be found here.

The full OCC Bank Supervision Operating Plan can be found here.

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