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Third-Party Risk Management Highlights from Spring 2022 OCC Semiannual Risk Perspective Report

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The Office of the Comptroller of the Currency (OCC) charters, regulates, and supervises national banks and federal savings associations and licenses, regulates, and supervises the federal branches and agencies of foreign banking organizations. Twice a year, the OCC publishes a Semiannual Risk Perspective Report. It addresses important issues faced by banks and focuses on risks that threaten banks' safety, soundness, and compliance with applicable laws and regulations.

Highlighted risk themes in the report include operational, compliance, interest rate, and credit risks:

  • Operational risks, including evolving cyber risks, are elevated, with increased attacks against financial services given current geopolitical tensions. Moreover, banks also face challenges due to "strong competition" in the labor market due to staffing challenges
  • Compliance risk remains high due to the current operational environment, regulatory changes, and policy initiatives
  • A moderate level of credit risk persists, and specific areas of weakness and potential longer-term consequences result from the Covid-19 pandemic, inflation, and the Russia-Ukraine war

Third-Party Risk Is an Ongoing Concern

The report also includes third-party risk as an ongoing concern. But, more specifically, it reports how the use of third parties directly impacts an organization's risk profile. Third parties are susceptible to the same cyber and many other risks that banks experience. For banks to address risk, they must clearly understand how third parties manage their risks.

OCC semiannual risk perspective report

Here are a few relevant excerpts from the report:

Third-Party Risk Management

"Third-party risk management continues to be an area of heightened supervisory focus. Before engaging with a third party, it is important for banks to conduct appropriate due diligence. The scope and depth of due diligence performed should be commensurate with the risks posed by each third-party relationship and the nature and criticality of the proposed activity."

Cybersecurity

"The risk to supply chain management operations continues to increase and evolve as attacks target vulnerabilities in software systems commonly used by large numbers of organizations. Threat actors are increasingly exploiting vulnerabilities in IT systems and third-party software to conduct malicious cyber activities while negotiating ransom payments. These attacks demonstrate the importance of banks assessing the risks emanating from their third parties, inclusive of the supply chain, and developing a comprehensive approach to operational resilience."

Compliance

"Bank compliance functions also are experiencing challenges retaining and replacing staff. A lack of access to subject matter expertise may result in increased compliance and operational risks, particularly if existing compliance processes, controls, testing, and training become subject to funding cutbacks or limitations, or if future compliance management program enhancements and maintenance are delayed. Additionally, compliance and operational risk may increase or evolve if banks begin using, or expand use of, third-party relationships for support or to fill critical roles, especially if banks do not conduct appropriate due diligence on third parties or select inexperienced or unqualified third parties."

It's clear the OCC expects banks to be aware of and manage their risks, and third-party risk management plays a substantial role.

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