OCC's Recent RFI: Modernize or Fall Behind

Hey, GonzoBankers. Tony DeSanctis back with another hot take.

So the OCC releases the Community Bank Digitization RFI. Is this just another regulatory form that we have to fill out?

I called Chris Miller, and he put a nice post out on LinkedIn. I’m going to quote from his LinkedIn post: “The OCC RFI is not a regulatory document. It’s a call to action for community institutions. Clinging to outdated systems isn’t a disadvantage. It’s an existential threat.”

Essentially, what the OCC is trying to do, we think based on the conversation I had with Chris, is get an idea of what some of the challenges are for community institutions in moving into this digital age.

What they’re going to do with this remains to be seen, but I think it’s worthwhile for all of us, including Cornerstone, to potentially respond to this.

They’re asking questions around 10 key topics. What is your digital plan? What’s your board and governance policy around it? What’s the due diligence and implementation plan for your new digital strategy? What are the costs and budgets associated with it? What third parties are you going to use to do it? What kind of competitive pressures are leading you to make these decisions?

AI and the role that’s going to play in this is going to be a part of it, along with legal implications, any risks associated with this from a compliance and customer experience perspective, and finally, what kind of data sharing is happening.

It’s a fairly extensive list of questions, but we do think it’s going to be critical as the OCC sets policy for digital strategy going forward.

So if you want to talk more about this, certainly reach out to Chris or myself. I think it’s worth exploring this and potentially looking at whether or not you, as an institution, should respond to this.

Let us know in the comments if you plan to respond or what questions you might have.