德勤：2023年银行监管展望报告_29页_5mb

2023 Banking Regulatory Outlook Summary

Core Content

The 2023 banking regulatory outlook highlights the ongoing efforts of federal regulators to address both core and emerging risks in the financial sector. Despite the challenges faced by the banking system in 2022, including inflation, rising interest rates, and the impact of the Russia-Ukraine conflict and the pandemic, banks have maintained adequate capital and liquidity levels, indicating resilience. However, concerns about systemic risk and the resolvability of non-G-SIBs remain, prompting renewed regulatory focus.

Main Views and Key Information

Regulatory Priorities and Expectations

• Systemic Risk and Resolvability: Regulators are emphasizing the importance of ensuring the resolvability of large banks, even those not classified as Global Systemically Important Banks (G-SIBs). This includes considerations of resolution requirements, such as single point of entry, total loss absorbing capital, and separability.
• Governance and Controls: Governance and controls are a central focus for 2023. The Federal Reserve Board (FRB), Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) have all identified these as priority objectives. The OCC classifies operational risk as "elevated," and supervisory plans will likely be based on these objectives.
• Regulatory Collaboration: Federal regulators are showing increased collaboration and are connecting themes across supervisory events to identify emerging risks. This collaboration is driving a "race to the top" in regulatory expectations.

Innovation and Technology

• Digital Assets and Crypto Activities: Federal regulators have issued a joint statement on crypto-asset risks, reinforcing previous regulatory views and drawing a clear line on the permissibility versus advisability of crypto-related activities. The joint statement includes a broad definition of crypto-assets and highlights key risks.
• AI and Fintech Integration: The use of AI and fintech tools is increasing in the banking sector, with potential applications in legal analysis, investment research, and customer service. Banks are also forming partnerships with fintech companies to enhance their services and access to regulatory assets such as FDIC-insured deposits.
• Regulatory Responses to Innovation: Regulators are using existing tools to enforce and protect the US banking system, with a cautious approach to new digital-asset product launches. Third-party risk management remains a key focus area.

Legislative and Regulatory Developments

• Congressional Efforts: In 2022, there was significant legislative activity aimed at clarifying the regulatory treatment of crypto-assets. However, no federal legislation was enacted. Stablecoin legislation is seen as a potential area of consensus.
• Global Context: The US is lagging behind the European Union and the United Kingdom in developing a comprehensive policy framework for crypto-assets. This may lead to increased legislative and regulatory actions in 2023.

Key Regulatory Areas

• Data Governance and Reporting: Regulators are demanding more frequent and granular data reporting, which is essential for effective risk management and crisis response. Banks must improve data quality and infrastructure to meet these expectations.
• Cyber and IT Risk: Cybersecurity is becoming a more pressing concern, with regulators pushing for stronger defenses and standardized incident response procedures. The "Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA)" is a notable development in this area.
• Consumer Protection and Financial Inclusion: These remain important areas of focus, with regulators ensuring that banks meet their obligations under the Bank Secrecy Act (BSA) and anti-money laundering (AML) requirements, as well as addressing broader consumer concerns.

Financial Risk Management

• Capital and Liquidity: Capital and liquidity remain core elements of financial risk management. Regulators are likely to continue monitoring these aspects closely.
• Climate-related Financial Risk: As climate change becomes an increasingly relevant factor, regulators are expected to incorporate climate-related financial risk into their supervisory frameworks.

Recommendations for Banks

• Engage in Regulatory Dialogue: Banks should engage in early and frequent dialogue with regulators to understand and comply with new requirements.
• Improve Data Quality and Infrastructure: Developing a firmwide data culture, migrating to a product-level view, and enhancing data governance and reporting are essential.
• Enhance Cybersecurity Measures: Strengthening cybersecurity policies and procedures, with increased board and senior leadership involvement, is critical.
• Invest in Technology and Talent: Banks should invest in IT infrastructure, cloud computing, and AI/ML capabilities to support their evolving needs.
• Align Strategy and Risk Appetite: Digital-asset strategies must align with the organization's overall strategy and risk appetite.

Conclusion

The banking sector is undergoing significant transformation due to technological innovation and regulatory scrutiny. While banks have shown resilience, they still have work to do to meet evolving supervisory expectations. The regulatory landscape is expected to become more active in 2023, with increased focus on governance, data management, and cybersecurity. Banks must proactively address these challenges to ensure long-term stability and compliance.