We are one of those institutions that has moved from OTS to OCC. One of the many questions we have is how differently the OCC views Risk Assessments. We've done well on our compliance exams the past several years, but wonder if what has been acceptable to the OTS might be viewed less favorably by the OCC.

Does anyone have any thoughts? Perhaps those who have worked for institutions regulated by each of those?

Thanks,

I am in the same boat and look forward to the answers, thanks for posting.

::takes seat in boat alongside the Queen::

:;pats chair for SF::

We are an OCC regulated bank. Bank size is about 1.3 billion. OCC wants detailed risk assessments and reviews them in detail.

Agreed. I spent many years in OCC banks of all sizes and they want detailed risk assessments that show the bank considered all risks and developed processes that respond to those risks.

Banks over 1 billion...definitely.

Less than 1 billion....slightly less.

We are hovering just above half a billion and the OCC is going after our IT department for not having a detailed RA on the initial set up of RDC. They are not happy.....

OCC came out with a bulletin 7 years ago about managing the risk process of New Expanded or Modified Bank Products or Services http://www.occ.treas.gov/news-issuances/bulletins/2004/bulletin-2004-20.html

It is a pretty good basic framework to follow.

Thanks for the reference.