OCC MLR

Has anybody heard anything from the OCC on the 2016 MLR?

No. Thought It would have showed up about 2 weeks ago.

They had calls in June. I sent an email a couple of weeks ago, was told they had not sent out anything yet. Of course they did not say when they would be sending it out I just keep looking at BankNet in case I miss an email or something.

Just received an e-mail with the following:

The Money Laundering Risk data collection process is about to begin with our compliancy policy department sending out the email reference starting Friday October 28, 2016. The MLR data collection cycle begins 11/7/16.

Good luck to all our national bank friends!

We just got our "Greetings" email today as well.

I haven't received the 2016 report or the request for the new one.

Here's to hoping they forgot about us.

Finished ours today!!

What do you guys honestly do with the MLR info?

Last year I had put together a presentation showing a three year trend to the compliance committee and to the board, but I question the value of it.

A lot of the info is that which other banks use as the fodder for their risk assessment. However, some of it is simply worthless. The OCC says it helps them to identify "higher" risk banks and that's probably true, but they represent such a small subset of OCC supervised banks that it is clearly unnecessary to require all OCC banks to provide the information. Instead, they could simply query those where major risk factors are readily apparent.

Agreed, we are very conservative in nature, even compared to our peers our data shows that our transactional volume is minimal when it comes to higher risk transactions and/or customers.