In its annual Bank Supervision Operating Plan, the Office of the Comptroller of the Currency ("OCC") listed several key areas of focus for FY 2020. The agency's fiscal year runs from October 1, 2019, to September 30, 2020.

The OCC's priorities include:

  • cybersecurity and operational resiliency and, in particular, addressing threat vulnerability and detection;

  • Bank Secrecy Act / anti-money laundering;

  • commercial and retail underwriting practices;

  • commercial and retail credit supervision;

  • the effects of changing interest rate predictions for bank activities and risk exposures;

  • preparedness for the anticipated phaseout after 2021 of the London Interbank Offering Rate (or "LIBOR") as a reference rate; and

  • technological developments.

Commentary

Conor Almquist

A recurring concern during the transition away from LIBOR has been the disconnect between the certainty present in regulators' public statements and the softened language in formal regulator policy materials. In the OCC's Bank Supervision Operating Plan, the LIBOR cessation is described as a "potential phaseout" that institutions should prepare for; this seems far off from Federal Reserve Bank of New York President John Williams' recent statement that there are three things in life guaranteed: "death, taxes, and the end of LIBOR."

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