(270) 506-5140 CONTACT US

The OCC Isn’t My Regulator - BUT They Still Matter to You

Apr 5, 2017 by Branan Cooper

The OCC came out with new guidance on January 24, 2017 - they published the supplemental examination guide for third party risk management, titled OCC Bulletin 2017-7. So, if you’re at a credit union, or even a bank regulated by another prudential regulator, you’re saying to yourself, “Wow, glad I’m not at an OCC institution.” Well, you’d be well advised to take note.

OCC Will Still Affect You

Here’s a piece of advice – the regulators follow one another for best practices and ideas just like your financial institution watches its peers. Truly, they do. We all keep up with best practices and common pitfalls – so why wouldn’t you expect the regulatory authorities to do so?

How do I know?

Here's a few examples from personal experience:

1. In most of my presentations, I end with an appendix of relevant third party guidance that includes many of the different regulators – I first saw the slides, which I’ve updated numerous times over the years, in an FDIC presentation.

2. When the guidance that is generally considered the gold standard for third party risk management came out – OCC Bulletin 2013-29 – it generated a lot of buzz among my regulator friends at the FDIC.

3. At the ABA Risk Management Conference in San Diego in the summer of 2016, I saw the well known “lifecycle” diagram from Bulletin 2013-29 in two different presentations, yet neither of the people who put that slide up were from an OCC regulated institution or the OCC.

4. OCC Bulletin 2017-7 has generated a lot of buzz in the industry. That's because...effectively, it takes the requirements laid out in OCC Bulletin 2013-29 and codifies them into supplemental examination procedures. These procedures will help everyone

Listening to ALL Regulators Will Save You

Keeping tabs on the best ideas is always a good move – if you know your program is good enough to pass the most stringent guidance, you know your institution will be safe. And, bonus - you’ll be surpassing your examiners’ expectations ...hopefully. It'll create some strategic advantages for you.

So, no matter which regulator you have, make sure you understand OCC Bulletin 2017-7...and use our guide to help you. Download that now. 

Guide on OCC Bulletin 2017-7

Branan Cooper

Written by Branan Cooper

Branan Cooper is the Chief Risk Officer at Venminder. Branan has nearly 30 years of experience in the financial services industry with a focus on the management of operational and regulatory processes and controls—most notably in the area of third party risk and operational compliance. Branan leads the Venminder delivery team as the third party risk management subject matter expert in residence. Branan also serves as an industry thought leader. He's a member of InfraGard and the Professional Risk Management Industry Association (PRMIA). And, he was selected in 2018 as an advisor to the Center for Financial Professionals (CEFPro) and board member for the Global Sourcing Resource Network (GSRN).

Follow Branan Cooper

Subscribe to the Venminder Blog