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Enhancing Audit Practices: Key Insights from the OCC Regulatory Highlights

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This presentation, led by Kathy Murphy and Paula Johnson from the Office of the Comptroller of the Currency (OCC), emphasizes the growing focus on audit practices in financial institutions. It outlines key regulatory highlights from 2013 and the evolving rules and expectations surrounding audits. Topics include the roles of various regulators, the importance of effective audit characteristics, increased supervisory attention to overlapping concerns, and essential updates in accounting policies. Attendees will gain insights into the current audit landscape and best practices for improved governance and risk management.

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Enhancing Audit Practices: Key Insights from the OCC Regulatory Highlights

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  1. IIA – DC Chapter Event Regulations and AuditMarch 26, 2014Kathy Murphy OCC Deputy Comptroller & Chief AccountantPaula JohnsonOCC Operational Risk and Core Policy Analyst

  2. Agenda • Increased Focus on Audit • 2013 Regulatory Highlights • On the Horizon

  3. Regulations & Audit Increased Focus on Audit • Reliance as 3rd line of defense • Multiple Regulators • Evolving Rules & Regulations • Effective Audit

  4. Increased Focus on Audit Supervisory Attention on Overlapping Areas of Concern Audit Compliance Mgt CRA/Fair Lending Audit Capital Planning Compensation Ops Risk Mang Enterprise Risk Mang 4

  5. Increased Focus on Audit Evolving Rules and Regulations

  6. Increased Focus on Audit Heightened Expectation themes • Accountability / Effective Challenge • Stature/Independence • Competence/Talent • Scope and Frequency

  7. Increased Focus on Audit Effective Audit Characteristics • Robust Board and Audit Committee (Committee) engagement/oversight • Strong audit management • Highly effective audit processes • Highly effective audit reporting • Competent internal audit staff

  8. Regulations & Audit Regulatory Highlights • Overview • OCC Accounting Policy • OCC Operational Risk & Core Policy

  9. Regulatory Highlights Overview

  10. Regulatory Highlights Accounting • Selected Bulletins • 2014-4: Clarification of the OCC’s expectations regarding secured consumer debt discharged in Chapter 7 bankruptcy proceedings • 2014-2: Mortgage Banking Comptroller Handbook • 2013-26: Interagency Supervisory Guidance Addressing Certain Issues Related to Troubled Debt Restructurings • 2013-23: Regulatory Capital Rule (Basel III) • 2013-20: OREO Comptroller Handbook • Bulletins can be obtained from OCC.gov (left side of the screen under key resources)

  11. Regulatory Highlights Accounting Volcker Rule & OTTI Accounting BAAS

  12. Regulatory Highlights Overview

  13. Regulations & Audit On The Horizon • OCC Accounting Policy • OCC Operational Risk & Core Policy

  14. On The Horizon Accounting • Policy Pipeline • Basel Committee on Banking Supervision - External Audit Document • ALLL Comptroller Handbook • Hot Topics • Appropriateness of the ALLL and Accrual Status • HELOC “End of Draw” • Sales/Creation of Mortgage Servicing Rights (MSRs) • Appraisals • Valuation, including funding valuation adjustments • New capital rule and other regulation changes

  15. On The Horizon Accounting • FASB Developments • Classification and Measurement • Current Expected Credit Losses (CECL) • Leases • EITF Matters (e.g., OREO, Foreclosed FHA Guaranteed Loans) • Private Company Council • Changes to PCAOB Auditing Standards • Auditor’s Report • Auditor’s Responsibilities Regarding Other Information and Related Amendments

  16. On the Horizon • Updating the Audit Booklet in the Comptroller Handbook • Risk Governance Framework Standards for Complex Banks – New Appendix to Part 12CFR30 • Updating the Internal Controls Booklet in the Comptroller Handbook • Updating The Director’s Book

  17. On the Horizon Internal & External Audit Booklet • Board and Management Oversight * • Audit Programs (types of audits) • Internal Audit Function (Oversight & structure) * - Independence and Competence * • Co-sourcing & outsourcing * • External Audit - Board & Committee Oversight, External audit opinions* • Annual 12CFR363 reporting * • Internal Audit Program - Audit Universe * , Audit Work Programs, Sampling Methods & Techniques * , Risk Scoring Methodology *, Follow-up Activities *, Professional Development Program* • Quality Assurance Program* • Continuous Auditing * • Reliance on Assurance Providers * - External & Internal assurance reports , Audit planning impact

  18. Summary Midsize Bank Audit Roundtable Increased Focus on Audit – rules and guidance, regulators, Heightened expectations themes, and effective audit elements 2013 Regulatory Highlights – accounting and operational risk/core policy highlights On the Horizon - Handbook updates Questions?

  19. IIA – DC Chapter Event Regulations and AuditMarch 24, 2014Kathy Murphy OCC Deputy Comptroller & Chief AccountantPaula JohnsonOCC Operational Risk and Core Policy Analyst

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