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With the advent of smartphones and the expansion of online and mobile banking, scrutiny over technology evolved. The very definition of what a bank is and could do was challenged by new financial technology companies, or fintechs, disrupting the way traditional banks do business. Other companies began delving into digital assets.
Examiners began promoting responsible innovation for banks to thrive in this environment. Bank information technology examiners had become a specialty by this period.
Additionally, the types of products and services banks provided in this new digital age increased the need for the OCC’s supervision over bank information security and required a new set of skills for examiners.
In 2020 the global pandemic shuttered millions of businesses and fundamentally changed how people lived and worked. In the face of pandemic-related travel restrictions, examiners adapted.
Technology advancements allowed examiners to stay connected with each other and their banks. They relied on enhanced market and credit monitoring activities to stay aware of and give prompt attention to potential adverse effects.
“I think there is one other reason the system has stood so well for so long. It’s because the OCC recognized in its earliest years, under its first Comptroller, a set of guiding principles that turned out to be as relevant in the age of the internet as they were in the days of the telegraph and horse-drawn wagon.” —Thomas J. Curry, Comptroller of the Currency, March 31, 2014
“I think there is one other reason the system has stood so well for so long. It’s because the OCC recognized in its earliest years, under its first Comptroller, a set of guiding principles that turned out to be as relevant in the age of the internet as they were in the days of the telegraph and horse-drawn wagon.”
Examiners encouraged banks to work with customers having loan difficulties. They made sure that exam reports reflected the steady stream of pandemic-related actions by the federal banking agencies to ensure that the federal banking system remained a conduit for capital, lending, and other assistance for consumers and communities.
Well-Educated Examiners today are well-educated. The OCC attracts some of the brightest people from the nation’s campuses and some of the most capable veterans of the financial services industry; 58 percent of OCC examiners have degrees in finance and accounting, 21 percent in business administration, and 15 percent in banking and financial support services.
A Unique Temperament Beyond academic skills, good bank examiners are endowed with a unique temperament. “I think of the examiner as a bit of a detective,” said Bonnie Russell, a former OCC recruiter. “When they arrive at a bank, they must dig for details, be persistent, and solve problems. They combine pieces of information, apply rules or laws, and draw conclusions. Often, they must find a relationship between seemingly unrelated information and events.”
Technically Sophisticated New OCC examiners also tend to be technically sophisticated. “This generation of examiners has grown up with technology,” said Jim Nowe, a bank information technology examiner. “They’re comfortable with the computer applications the OCC uses in its daily supervisory business. And they’re fluent and at ease in speaking to bankers about information security, deposit and loan processing controls, electronic privacy issues, and intrusion detection and prevention.”
Banking is a business of managing risk, and a bank’s risk identification, assessment, monitoring, and management affect the condition of the federal banking system as well as each bank’s individual performance.
A National Bank Examiner focuses on evaluating banks’ ability to identify, measure, monitor, and control risks. The OCC monitors the condition of the federal banking system, identifies and assesses key supervision risks, and takes actions to respond to those risks.
The key for National Bank Examiners with any new financial product or service at each point in history has been to understand the impact new developments have on a bank’s risk exposures.
As these risks evolve and shift over time, the OCC’s examiners develop new knowledge reflected in emerging areas today like understanding crypto-assets and monitoring climate-related risks to financial stability.
Supporting OCC examination staff is a nationwide network of lawyers, economists, analysts, specialists, accountants, policy experts, and support staff who together make the OCC the world’s preeminent prudential supervisor. This network brings a broad national perspective to complement the deep local expertise of the assigned exam teams.
The OCC continues to build on its past, refining its practices to be relevant in the present and prepare for the future. Doing so bolsters the value of a national bank charter and enables the agency to meet its mission for many years to come.
