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Take Aways from OCC Risk Report



# What Credit Unions Can Learn from the OCC's Spring 2024 Semiannual Risk Perspective


The Office of the Comptroller of the Currency (OCC) recently released its Spring 2024 Semiannual Risk Perspective, providing valuable insights into the current state of the banking industry. While the report focuses on OCC-supervised banks, there are several key takeaways that credit unions can apply to their own risk management strategies.


## 1. Economic Landscape and Its Impact


The U.S. economy has shown resilience, outperforming forecasts in 2023. However, the OCC notes that growth is expected to slow in 2024. For credit unions, this means:


- Prepare for potential economic headwinds

- Monitor local economic indicators that may affect members' financial health

- Stress test loan portfolios under various economic scenarios


## 2. Credit Risk Management


The OCC report highlights increasing credit risk, particularly in commercial real estate (CRE) and certain consumer sectors. Credit unions should:


- Review and potentially adjust CRE lending strategies, especially for office and multifamily properties

- Enhance monitoring of loans set to refinance in the next three years

- Assess the impact of persistent inflation and elevated interest rates on members' ability to repay loans


## 3. Interest Rate and Liquidity Risk


Banks are facing pressure on net interest margins (NIMs) due to strong deposit competition. Credit unions can:


- Review and optimize deposit pricing strategies

- Enhance liquidity risk management, including contingency funding plans

- Assess the impact of potential interest rate changes on the balance sheet


## 4. Operational Resilience and Cybersecurity


The report emphasizes the importance of operational resilience and cybersecurity. Credit unions should:


- Strengthen cybersecurity measures, including multi-factor authentication

- Develop and regularly test comprehensive business continuity plans

- Ensure adequate staffing and expertise in IT and cybersecurity roles


## 5. Innovation and Digital Transformation


Banks are leveraging new technologies to meet evolving customer expectations. Credit unions can:


- Evaluate opportunities for digital transformation while managing associated risks

- Implement robust third-party risk management processes when partnering with fintech companies

- Consider the compliance implications of new products and services


## 6. Fraud Prevention


Payment systems fraud remains a significant concern. Credit unions should:


- Enhance fraud detection systems, especially for digital and faster payment channels

- Educate members about potential scams and fraud risks

- Review and strengthen authentication processes for digital banking services


## 7. Compliance and Fair Lending


The OCC emphasizes the importance of fair and equitable delivery of financial services. Credit unions should:


- Review fair lending practices, especially when using AI or machine learning in lending decisions

- Ensure compliance management systems evolve with changing products and services

- Stay informed about potential changes to regulations, such as the Community Reinvestment Act


## 8. Climate-Related Financial Risk


While this may be a newer area for many credit unions, the OCC's focus suggests it's gaining importance. Credit unions can:


- Begin assessing potential climate-related risks in their loan portfolios

- Monitor insurance trends in high-risk areas that may affect members or collateral


## Conclusion


While credit unions operate under a different regulatory framework than OCC-supervised banks, the risks and challenges highlighted in the OCC's report are relevant across the financial services industry. By proactively addressing these areas, credit unions can enhance their risk management practices, better serve their members, and position themselves for sustainable growth in an evolving financial landscape.


Remember, the key to effective risk management is to tailor these insights to your credit union's specific size, complexity, and market conditions. Regular risk assessments and open communication with your board and supervisory authorities are crucial in navigating the current financial environment.

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