The OCC’s Semi-annual Risk Perspective - Trends in Key Risks
Samantha: Hello, this is Samantha Shares.
This episode covers the
O C Câs Semi-annual Risk
Perspective, Trends In Key Risks.
The following is an audio version
of that section of the report.
This podcast is educational
and is not legal advice.
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The office of the Comptroller
of Currency â the O C C issues
a semi-annual Risk Perspective.
This past Decemberâs report has many key
sections and todayâs podcast highlights
the section called Trends in Key Risks
And now the report.
A.
Credit Risk.
COMMERCIAL CREDIT THEMES.
Commercial credit risk remains
moderate and increasing.
While recessionary pressures
are easing, the consensus among
economists is that the U.S.
economy will experience slowing growth,
which will affect vulnerable borrowers.
Inflation remains elevated, and many
economists predict that interest
rates will remain higher for longer.
Wages remain a primary cost driver, and
companies in the service industries are
the most affected by higher labor costs.
Operating margin deterioration
is particularly evident in senior
living and health care facilities,
which are experiencing both wage
inflation and staffing shortages.
Elevated interest rates also continue
to have an adverse impact on some
companiesâ profit margins and cash flow.
The companies most affected are those
with high leverage and marginal repayment
capacity, smaller and lower-rated firms
with shorter debt maturities, firms with
a higher level of floating debt, and
firms with limited financial flexibility.
An obligor on a maturing loan with
a balloon payment will likely need
to demonstrate a higher repayment
capacity at renewal or refinance due
to higher debt costs and, for CRE
loans, lower property values could
also lead to the need for re-margining.
Renewed loans should be
appropriately risk-rated.
The liberal use of extensions and
renewals could mask credit weaknesses
and obscure a borrowerâs inability
to meet reasonable repayment terms.
Generally, risk ratings are driven
by the strength of the primary source
of repayment rather than collateral
value or strength of guarantor.
The Federal Reserve has not ruled
out additional federal funds rate
hikes if inflation remains elevated.
Manufacturing production and
new order indexes are declining.
Further rate hikes would continue
to increase the cost of business
investment and consumer goods,
placing downward pressure on demand.
Demand-side shocks for industries
and companies already under stress
from high input costs or higher
interest rates create the potential
for a rapid and sustained decline
in cash flow and profitability.
The sustained period of price
increases will likely serve as a
drag on revenues for a wide range of
industries, particularly growth-dependent
borrowers and industries that are
dependent on consumer discretionary
spending, if consumers significantly
curtail spending across the board.
Credit quality metrics for C R E in
some markets show signs of deterioration
as persistent headwinds threaten
asset quality and loan performance.
C R E concentrations increased steadily
over the past 18 months, and refinance
risk is heightened due to higher debt
costs and increases in operating expenses.
Expenses, including utilities, property
insurance, and taxes, are rising.
Increasing debt costs are driven by higher
interest rates and lower valuations.
In June 2023, the O C C, the Federal
Reserve, Federal Deposit Insurance
Corporation, and National Credit Union
Administration published the âPolicy
Statement on Prudent Commercial Real
Estate Loan Accommodations and Workouts.â
The final interagency policy statement
updates and builds on existing interagency
guidance on C R E loan workouts
calling for banks to work prudently and
constructively with creditworthy borrowers
during times of financial stress.
Risk in the office market
remains high and is expanding
beyond urban business districts.
Although risk remains highest in
urban core markets, vacancy rates
are rising for suburban submarkets.
Data suggest that the office sector
is experiencing significant structural
shifts that could take several years
to fully materialize as new remote
work practices normalize and office
loans made before 20 20 mature.
Leases reflect smaller footprints
for businesses as tenants seek
less square footage per employee.
There is some resiliency in
5-star and newer buildings, but these
leases often include concessions and,
because of low demand, could negatively
affect less well-situated properties.
Retail and other small business real
estate in urban business districts
that are reliant on office worker foot
traffic have higher and rising vacancy
rates than suburban submarket peers.
Risk in the multifamily market is
increasing, with higher vacancy
levels due to a combination of
new inventory and slowing demand.
Mortgage delinquencies for
multifamily properties remain
low but are starting to increase.
Multifamily real estate risk varies by
market, property type, and other factors.
Senior housing continues to struggle
as health care worker shortages
exacerbate real estate risk factors.
Some parts of the United States, such
as Phoenix and Salt Lake City, are
experiencing an overbuild in luxury
properties, which leads to further
devaluation for older properties.
Other C R E markets remain sound
but show signs of softening.
The industrial market, which has been the
best performing C R E segment, is also
starting to exhibit some signs of slowing.
Overall industrial vacancy rates remain
low, and it is uncertain whether the
market is reaching an inflection point
or reverting to a normalized level.
Just as with other C R E property
types, however, rising interest
rates will have a negative impact on
cash flows and valuations and will
increase project financing costs.
While some retail property
types have stabilized, regional
malls continue to struggle.
A heightened risk environment could
strain the resources of credit risk
review and loan workout functions.
Retirements and other attrition,
coupled with an extended benign
credit period, have decreased the
number of bankers with problem loan
identification and mitigation experience.
Credit risk review functions may
need to adjust sampling methodologies
to capture higher risk industries
or segments, borrowers who become
constrained under stress test scenarios,
or borrowers who exhibited marginal
repayment capacity at origination or
during stronger economic conditions.
Workout functions could experience
quickly increasing workloads that
warrant additional experienced staff.
Regardless of whether problem loans are
part of a formal loan workout, accurate
and timely risk ratings are a key factor
in successful credit risk management and
are critical for problem loan mitigation.
RETAIL CREDIT THEMES.
Retail credit performance remains
satisfactory and has largely
normalized across all asset classes.
Lagging asset quality indicators
have largely returned to
pre-pandemic levels and remain
in line with long-term averages.
Portfolio growth moderated, with banks
reported to have tightened underwriting
standards earlier in 2023 in response
to uncertain economic forecasts.
Credit risk, including rising credit
card and auto delinquencies, is
moderate and remains manageable.
Effective risk management practices,
including stronger residential real
estate underwriting since the Great
Recession and the low rate refinancings
done during the pandemic, will
support homeownersâ repayment ability
and better position banks to manage
through current economic challenges.
The strong labor market, rising wages,
manageable debt levels, and elevated,
but declining, cash reserves enabled U.S.
consumers to withstand costs
associated with the level of
inflation and rising interest rates.
Credit card and auto delinquencies,
however, increased in most banks
in 20 23 and are increasing.
More material credit deterioration
is evident in banks with higher risk
appetites and more nonprime strategies.
Retail net charge-offs, primarily
driven by credit cards, have increased
steadily each quarter for the past year.
The most vulnerable segments of
households continue to be those in
lower income brackets, on a fixed
income, or more highly leveraged.
Higher interest rates on new
originations and upward adjustments
on variable rate debt, along with
the potential for declining asset
values, could place additional pressure
on certain consumer and mortgage
borrower segments and loan vintages.
The resumption of federal student
loan payments in October 20 23 and the
discontinuation of other government
support programs pose uncertainty
regarding the potential impacts
on some borrowersâ ability to pay.
The new Saving on Valuable Education
(SAVE) program is anticipated to reduce
student loan payment shock by limiting
payments to 5 percent of discretionary
income, increasing the amount of
income considered non-discretionary,
and accelerating loan forgiveness.
Banks should evaluate the risk
that consumersâ student loans
payment resumption may impact
repayment of their other bank loans.
Additional considerations include
the risk inherent in new loan
applications where missed student
loan payments will not be reported
to the credit-reporting companies as
delinquencies, and borrowers will not be
considered in default for the next year.
Residential real estate loan portfolios
demonstrate satisfactory performance.
Consumer home loans reflect sound
underwriting; and overall portfolio risk
metrics reflect satisfactory support
from the level of homeowner equity.
Stress testing vulnerable vintages,
segments, and geographies, on variables
such as unemployment, declining
collateral values, and inflation impacts
on disposable income, is an effective
tool to identify weaker
portfolio segments.
If identified, weaker segments warrant
monitoring, incremental adjustments
to underwriting, and an emphasis
on safe and sound principles in the
execution of loss mitigation programs
to provide prudent, affordable, and
sustainable borrower payment assistance.
Borrower payment assistance programs for
retail loan products take many forms.
Effective loss mitigation programs
accurately address financial hardship
and underwrite the loan to the borrowerâs
willingness and ability to pay the debt.
Prudent programs verify the borrowerâs
sources of income, total debt, and
contractual payments, which support
affordability and should result in
sustainability of the borrowerâs
ability to repay their debt.
Loss mitigation programs based on
unverified information and lacking
sufficient repayment analysis are
inappropriate, and reliance on
extended amortization, extensions,
and deferral of unpaid amounts
reflect a borrowerâs lack of repayment
capacity and may not be in the best
interest of the borrower or the bank.
Imprudent loss mitigation programs
can result in less effective
risk oversight and reporting.
Bank management should remain
focused on accurate and timely risk
identification utilizing delinquency
reporting, risk rating, loss
recognition, and financial reporting.
Market Risk.
The speed and magnitude of rising rates
have materially influenced depositor
behavior and rate sensitivity in
direction and magnitude inconsistent
with historic observations.
Banks are facing significant deposit
competition from higher-yielding
choices as well as reduced broader
market liquidity, which may
further pressure banksâ deposit
retention and growth strategies.
Deposit competition has pushed
rates higher and resulted in
increasing usage of higher cost CDs,
brokered deposits, and borrowings.
Banksâ NIM could be further pressured from
continued market liquidity contraction,
high and steady or increasing short-term
rates, and a continued increasing trend
in deposit rates and funding costs.
Deposits as a percentage of assets in O
C C-supervised institutions stabilized
at 79 percent through the third quarter
of 2023 after trending down from a
peak of 82 percent at year-end 2021.
This stabilization was supported
by increased brokered deposit
and wholesale funding usage.
Between year-end 2022 and September
30, 2023, borrowings in O C
C-supervised institutions increased
172 billion dollars (29 percent)
and brokered deposits increased
258 billion dollars (55 percent).
Rising deposit rates and
increased reliance on
wholesale funding significantly
increased funding costs through
the third quarter of 2023.
Banks with assets under 1 billion
dollarshad a 91 basis point (131
percent) increase in funding
costs while banks with assets over
1 billion dollars saw a 112 basis
point (100 percent) increase.
Increased funding costs observed in 2023
compressed NIMs in smaller institutions,
despite rising asset yields, after
significant NIM expansion in 2022.
The median NIM (quarterly annualized)
in banks with assets between 10
billion dollars and 50 billion dollars
declined 35 basis points to 3 point
14 percent, while banks with assets
less than 10 billion dollars saw a
reduction of 22 basis points to 3.
point 0 percent.
Banks with assets greater than 50
billion dollars actually had a modest
improvement of 6 basis points in the
third quarter, bringing median NIM to 3.10
percent and nearly back to the 3 point
12 percent observed at year-end 2022.
Stress testing and sensitivity analyses
of deposit assumptions remain critical
given recent trends in deposit movement
and rates as well as uncertainty regarding
depositor behavior moving forward.
Banks may experience continued
pressure to raise deposit rates
contemporaneously and at higher levels
than forecasted relative to market rate
changes to grow or retain deposits.
These factors may continue to compress
margins, elevate risk to earnings, and
present new challenges for banks to
model and project deposit rates and
balances in both interest rate and
liquidity risk stress testing scenarios.
Inaccurate deposit assumptions will
render model results unreliable and
may mask banksâ true interest rate
risk and liquidity risk profiles.
Unreliable model projections and stresses
may result in higher-than-forecast
funding costs, potentially
unexpected liquidity shortfalls, and
imprecision in balance sheet hedging.
Sound liquidity risk management,
including processes that ensure sufficient
committed capacity to meet contingent
liquidity needs, remains critical.
Asset liquidity stabilized in 2023
and has been buoyed by increased
wholesale funding reliance.
Unrealized losses in OCC-supervised
institutionsâ investment portfolios
were negatively impacted by continued
increases in the 10-year U.S.
Treasury rates and remain a concern.
The current elevated levels of bank
investment portfolio depreciation
could exacerbate risk exposure,
particularly if security sales are
required to meet funding outflows.
Unrealized losses (as a percentage of
amortized cost) in O C C-supervised
institutionsâ available for sale
(AFS) portfolios increased in the
third quarter of 2023 and remain
elevated at 8 percent, while unrealized
losses in held-to-maturity (HTM)
portfolios increased to 16 percent.
Unrealized investment portfolio
losses highlight the importance of
operational readiness to monetize
securities in a timely manner in
case liquidity needs arise, to
avoid recognizing unrealized losses.
Examples include repo lines, Federal
Home Loan Bank (FHLB) capacity, and
access to Federal Reserve facilities.
Regular testing and capacity
assessments will help ensure these
sources remain accessible.
This is particularly important for banks
with large HTM holdings, as sale of
these securities can taint the portfolio
and lead to recognition of losses.
Operational Risks: CYBERSECURITY
Operational risk continues to be elevated
as cyberattacks evolve and become more
sophisticated and pervasive to the U.S.
economy.
Continuing cyberattacks and current
geopolitical tensions highlight the
importance of heightened threat monitoring
and safeguarding against disruptive
attacks targeting the financial sector.
Over the past year, there has been
an observed increase in distributed
denial of service (DDoS) attacks
against the financial sector.
Some of the increase may be attributed
to politically motivated attacks
while others are financially driven,
coupled with extortion demands.
Ransomware actors continue to
affect the sector by targeting
banks and their third parties.
These attacks have the potential to
affect banks and market operations by
rendering critical data inaccessible as
well as by threatening the confidentiality
of customer data through data leaks.
Single cyber campaigns have
demonstrated the ability to
compromise hundreds of organizations
and affect a significant number
of consumers.
Threat actors continue to leverage
phishing emails and texts targeting
employees and compromised credentials
to gain access to networks
through remote access solutions.
Such unauthorized access would enable
threat actors to conduct ransomware
and other extortion campaigns
that can affect bank customers.
Malicious actors have also
continued to use DDoS attacks
to target the financial sector.
Threat actors continue to exploit
publicly known software vulnerabilities
and weak authentication controls at
targeted organizations, including
banks and financial service providers.
To mitigate against cyber risks, it is
important for banks to adopt heightened
threat and vulnerability monitoring
processes and implement effective
security measures, including the use
of multifactor authentication (M F A),
hardening of systems configurations,
and timely patch management.
The OCC continues to see
cybersecurity incidents that
exploit weak or poorly configured
authentication controls and practices.
Recent attacks suggest that banks using
single-factor authentication or relying on
weak security methods may face increased
risk of unauthorized access to information
systems, potential operational disruption,
data compromise, or financial loss.
The O C C encourages banks to conduct
thorough risk assessments that
include authentication practices.
When consistently implemented, properly
configured, and combined with other
layered security controls, M F A can
provide an enhanced level of protection
and help prevent attacks on bank systems.
INNOVATION AND ADOPTION OF
NEW PRODUCTS AND SERVICES
Banks continue to leverage new technology
and innovative products and services
to further their digitalization
efforts and to meet evolving
customer demand and expectations.
Examples of innovations include
faster and real-time payment products,
increased use of mobile and digital
technologies to deliver financial
services, application programming
interfaces, data aggregation services,
AI, and contactless payment devices.
While these products and services
and their underlying technologies
can offer many benefits to banks and
their customers, they also contribute
to a complex operating environment
along with increasing compliance,
reputational, strategic, and other risks.
It is important to assess how
technology can be leveraged to fuel
rapid deposit outflows and how the
use of social media and other digital
channels may accelerate communications.
Banks are also reminded to implement
appropriate due diligence, change
management, and risk management processes
when considering changes to products,
services, and operating environments.
Banks have approached AI
adoption cautiously, with
a wide range of use cases.
The use of AI has the potential to
reduce costs and increase efficiencies;
improve products, services, and
performance; strengthen risk management;
and expand access to credit and
other banking products and services.
AI systems may, however, present
particular challenges related
to bias and discrimination.
For example, these systems may
perpetuate or exacerbate the results
of historical discrimination if
they are improperly trained or used
with data sets that reflect biases
or past discrimination practices.
Use of generative AI is becoming
more accessible with the
introduction of commercially
available large language models.
Like with all new or expanded
products, services, and relationships,
appropriate risk management
processes, including due diligence
and change management, are needed.
Banks and service providers continue to
face challenges with maintaining legacy
technology architectures while responding
to increasing digitalization demands.
It is important for banks to maintain
appropriate operational resilience for
on-premises and critical third-party
technology architecture, commensurate
with the size and complexity of products,
services, and operations being supported.
An effective operational resilience
strategy can enhance a bankâs ability
to mitigate disruption from all hazards,
including cyber threats, and other
technology and operational outages.
Sound risk management practices can
help safeguard against fraud, financial
crimes, and operational errors.
While traditional payment channels,
such as checks and wire transfers,
continue to be targeted, increasing
digitalization of products and services
can also heighten risk of fraud and
error, including fraud targeting P2P
and other faster payment platforms.
While P2P payment platforms can
provide enhanced capabilities and
convenience to consumers for managing
payments, the faster and streamlined
payment capabilities and the
irreversible and irrevocable nature
of these payments have also been
used to perpetuate consumer fraud.
Banks can aid customers by strengthening
controls, educating customers on
potential scams, and enhancing
internal fraud monitoring capabilities.
Examiners will continue to assess how
banks are managing these and other
risks related to changes in operating
environments driven by these innovations.
The O C C continues to approach
crypto-asset products, services, and
activities cautiously for a variety
of reasons, including high volatility,
high-risk lending, excessive leverage,
interconnectedness, concentration
within the crypto industry, and
lack of comprehensive regulation.
Banks are reminded to follow the process
outlined in O C C Interpretative Letter
1179 before engaging in permissible
crypto-asset-related activities.
THIRD-PARTY RISK MANAGEMENT
AND OTHER OPERATIONAL RISKS
Digitalization and technological
innovation continue to advance the trend
of banks outsourcing technology operations
and banks entering partnerships or other
arrangements with third parties, including
fintech firms, to deliver innovative
financial products and services.
For example, increasing adoption
of cloud services in the financial
sector, as noted in a recent U.S.
Department of the Treasury report, is
allowing banks to gain efficiencies, but
also can present risk if not implemented
properly.The complexity of bank-fintech
partnerships is also increasing as
the volume of new entrants within the
fintech ecosystem continues to grow.
Effective management and oversight are
important for third-party relationships.
Third- party risk management processes
should be commensurate with the
size, complexity, and risk profile
of the bank and with the nature
of the third-party relationship.
It is also important for banks to
engage in more rigorous oversight of
third-party relationships that support
higher-risk and critical activities.
In addition, it is important for
banks to maintain talent management
strategies to ensure sufficient
resources and subject matter expertise
to implement critical controls.
Given demand for staff with specialized
experience and technical expertise,
it may sometimes be necessary for
banks to engage with a third party.
Compliance Risk: BANK SECRECY
ACT/ANTI-MONEY LAUNDERING AND
OFFICE OF FOREIGN ASSETS CONTROL
COMPLIANCE RISKS
Banks continue to adopt or consider
fintech relationships related to product
and service offerings, and it is import
that they effectively manage the resulting
operational and compliance risks,
including third-party risk management.
It is important that banks understand
the benefits and risks associated
with each third-party relationship,
with particular focus on relationships
that involve higher-risk or critical
activities, and that they enter into
effective contracts addressing the
potential for default and termination.
It is also important for banks
to identify potentially nested
relationships where a fintech firm may
be providing services to other fintech
firms without appropriate controls.
As the range of payment methods and
their accessibility continue to expand
and evolve, for example with the launch
of instant payments via FedNow, it
is important that banks continuously
evaluate their BSA/AML risks and
corresponding controls to keep pace
with new or changing risk profiles.
While banks continue to expand their
digital and electronic products, services,
and capabilities, they should be aware
of related risks, including a recent
alert issued by the Financial Crimes
Enforcement Network (FinCEN) highlighting
a prominent virtual currency investment
scam known as âpig butchering.â Banks
also should remain vigilant against
traditional financial crime risks.
There have been significant increases
in fraud, as highlighted in both
a FinCEN alert on the nationwide
surge in mail theft-related check
fraud schemes, and a FinCEN analysis
identifying threat patterns and
trends related to business email
compromise in the real estate sector.
FinCEN also has noted increases in payroll
tax evasion and workerâs compensation
fraud in the construction sector.
Suspicious activity report (SAR) data
trends reflect significant increases
in SAR filings related to fraud.
Effective processes to prevent,
identify, and file SARs in a timely
manner, including fraudulent activity,
remain important to protect financial
institutions, consumers, and the
financial system, as indicated
by the fact that fraud is one of
FinCENâs National AML/CFT Priorities.
Banksâ responsibilities under the
current Customer Due Diligence and
Beneficial Ownership Rule and other
existing BSA requirements remain
unchanged, pending the issuance of
changes to those regulatory requirements
as required by the AML Act of 2020.
CONSUMER COMPLIANCE AND COMMUNITY
REINVESTMENT ACT/FAIR
LENDING (CRA/FL) RISKS
Banks continue to face heightened
attention and focus on ensuring
equal access to credit, and fair and
consistent treatment of consumers as
they adapt to changing customer needs
and preferences related to product,
service, and delivery channel offerings.
Risks are compounded if changes
are not delivered or implemented
in a fair or equitable manner.
Banksâ compliance risk management
frameworks should be commensurate
with their existing risk profiles and
capable of efficiently and effectively
supporting risk profile changes.
Additionally, as interest rates
continue to rise, banks may experience
an increase in relief requests
under the Servicemembers Civil
Relief Act on certain obligations
or liabilities incurred before the
servicemember entered military service.
In particular, borrowers may seek
relief for adjustable-rate credit
products such as credit cards
and for eligible auto payments.
On October 24, 2023, the O C C, the
Federal Reserve, and the F D I C issued
a final rule to strengthen and modernize
regulations implementing the C R A.
The effective date of the rule is
April 1, 2024, with key provisions of
the final rule going into effect on
January 1, 2026, and January 1, 2027.
It is important for banks to plan
for changes that become effective on
April 1, 2024, and to implement change
management processes as appropriate
to address the potential impact of the
rule on bank systems and resources.
Climate-Related Financial Risk
FINAL INTERAGENCY PRINCIPLES
FOR CLIMATE-RELATED FINANCIAL
RISK MANAGEMENT FOR LARGE
FINANCIAL INSTITUTIONS
On October 24, 2023, the O C C, F D
I C, and Federal Reserve issued final
Interagency Principles for Climate-
Related Financial Risk Management
for Large Financial Institutions
that provide a high-level framework
for the safe and sound management
of exposures to climate-related
financial risk for financial
institutions with total consolidated
assets over 100 billion dollars.
The principles support large financial
institutionsâ efforts to focus on key
aspects of climate-related financial
risk management, providing a high-level
framework for climate- related financial
risk management consistent with the
agenciesâ existing rules and guidance.
OBSERVATIONS OF LARGE BANKSâ MANAGEMENT
OF CLIMATE-RELATED FINANCIAL RISK
As noted in our Spring 2023 Semiannual
Risk Perspective, the O C C has been
conducting supervision activities at
its largest banks (those with over 100
billion dollars in total assets) to
understand the banksâ climate- related
financial risk management programs.
This work is well underway
and will continue in 2024.
As we stated in the spring, the
large banks have been making progress
to incorporate climate-related
financial risks in their risk
management frameworks and policies.
At the same time, the large banks overall
have significant additional work to
do to move those programs to maturity.
Observations to date include:
Efforts to incorporate climate-related
financial risk in strategic planning
remain in the early stages of development.
Most of these banks are also
still in the early stages of
integrating climate-related financial
risk into their broader risk
appetites, and some have developed
quantitative risk appetite metrics.
Banks are reporting on climate-related
financial risk to senior management and
the board and indicated that reporting
will become more detailed moving forward.
Banks continue to face challenges
and limitations on obtaining granular
data for their climate-related
financial risk analysis.
Banks have generally developed or are
planning to implement climate-related
credit risk assessments to evaluate
borrowersâ and clientsâ exposures
to high-risk sectors and industries.
Banks are in the very early stages
of understanding the impacts of
climate change and ways to mitigate
climate-related financial risk on low- and
moderate-income communities they serve.
Bank management teams generally
have focused their initial work on
the physical risks (e.g., flooding)
of residential real estate.
This concludes the O C Câs Risk
Perspective Report Section 4.
If your Credit union could use assistance
with your exam, reach out to Mark Treichel
on LinkedIn, or at mark Treichel dot com.
This is Samantha Shares and
we Thank you for listening.
