Blake Paulson, the new Chief National Bank examiner with the Office of the Comptroller of the Currency  (OCC) and senior deputy comptroller for midsize and community bank supervision, recently spoke with Law360 on the OCC’s plan beyond the coronavirus, detailing the steps the agency and banks can take to prepare for the next financial downturn.
According to Paulson, one of the most significant priorities of the OCC has been strengthening the Community Reinvestment Act regulation.
“We've done a tremendous amount of work to first put out an advanced notice of proposed rulemaking to request, which was a series of questions on the CRA and then a proposed rule. Now we've gotten all those comments back, and we're working on drafting the final rule. We expect that, working in conjunction with the FDIC [Federal Deposit Insurance Corporation ], we will release a final rule this year."
Paulson also notes that with increased forbearances may come increased risks.
“We're seeing a lot of forbearance activity relative to mortgage loans, auto loans, consumer loans and commercial loans,” Paulson notes. “Banks are providing various types of forbearance, such as loan restructurings.”
Beyond the technical and legal requirements, Paulson notes, banks need to assess risk as it's building in their loan portfolios, accurately risk-rate loans and ensure they have appropriate loan-loss reserves. Those are the primary areas where banks and examiners will be focused as we move into challenging economic times.
According to Paulson, the OCC is addressing liquidity in a number of ways.
“To start with, we want to understand how the bank views this,” Paulson states. “What's their analysis? What's their risk assessment in a stress-type scenario? What have they done to think about how much liquidity they should have on hand?”
“We would challenge that analysis and likely come to some type of an agreement for what the bank should have for liquidity and, if the bank agrees to that, we might include what we refer to as a matter requiring attention in the reported examination explaining our concerns, including what the bank committed to do about it and a time frame for that commitment,” he continues.