OCC's Curry Vows to Lessen Burden on Small Banks

WASHINGTON — Comptroller of the Currency Thomas Curry acknowledged Thursday that his office needs to better cater to community banks, including improving their communication with local examiners.

Curry said banks should "regularly" seek out their local examiners beyond the typical quarterly talks, and be more vocal on proposed and final rulemakings.

"We need to do a better job on those kinds of issues so that you can continue to do your job of serving consumers, businesses, and local economies across the United States," Curry told the Independent Community Bankers of America conference in Las Vegas. "I think the future is bright for well-managed community banks and thrifts, and the OCC stands ready to do everything we can to help assure that future."

Curry said that they've tried to make the process "more manageable," such as breaking down the proposed Basel III rulemaking into three separate issuances and separating out smaller banks from certain requirements. He encouraged bankers to offer suggestions at the conference as well as actively seek out dialogue with local OCC officials.

"We have offices in more than 60 cities across the country, and the examiners based in these offices know your local markets as well as anyone. They know your business strategy, and they can talk to you about risks and opportunities that they see," Curry said. "While they are locally based, they have access to a nationwide organization with all of the resources that entails, from liquidity specialists to licensing experts to legal counsel."

Many community bankers have argued in recent years that examination decisions are now being made in Washington rather than with local examiners, making it difficult for bankers to communicate their concerns. While bankers have more recently said communication has improved, Curry also assured them that the OCC has a "rock solid" commitment to community banks and thrifts.

"I know there will be times when you disagree with a finding in an exam report, and I won't try to argue that we're perfect," Curry said. "But as I have gotten to know our supervision group better and better, I have been deeply impressed not only with their professionalism, but with their commitment to help assure the viability of community national banks and federal thrifts across our country."

Curry also encouraged bankers to attend community banking workshops and review publications such as a recently released booklet called "Common Sense Approach to Community Banking." The OCC is sending out copies of the booklet to community bankers in the coming weeks. It covers key concerns with the OCC, including risk management, mapping out a business plan with sufficient capital support and understanding the supervisory process.

"Identifying, monitoring, and managing risk seems fundamental, but in practice it requires considerable experience and discipline, and some institutions are measurably better at it than others," he said.

Curry said the booklet should be used as a starter guide, saying each bank's risk management system should be tailored to the individual institution. He reiterated that a bank's senior management and board are responsible for risk management.

"A strong risk culture is proactive, and it drives the way your bank sets strategy and makes decisions. It also translates into how your management team and employees anticipate and respond to risk throughout the bank," Curry said. "Ultimately, your risk culture and risk management activities should result in the board's ability to understand material risks facing your bank and assist you in making key business and strategic decisions."

Curry fielded one question — from incoming ICBA Chairman William Loving Jr. — that dealt with the OCC releasing a final rule on capital levels. Curry used the moment to applaud community bankers for expressing concerns about Basel III, reassuring attendees that the agency was listening. He said bankers should expect a final rule in the spring.

"At the end of the day, we recognize how important it is for bankers, community bankers in particular, to know the rules have been adopted with a clear understanding of the impact on the entire industry and particularly community bankers," Curry said.

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