Comptroller of the Currency

Administrator of National Banks 

US Department of the Treasury 

The OCC’s 

Strategic Plan 

September 2011 

Office of the Comptroller of the Currency 

Washington, DC 20219 
Contents

Message From Acting Comptroller John Walsh...........................................................................1 

The OCC Today ...............................................................................................................................2 

Condition of the Banking Industry ...........................................................................................2 

The OCC’s Mission and Vision .....................................................................................................4 

Strategic Goals and Their Objectives and Strategies for Achieving the Goals ..........................5 

I: A Safe and Sound System of National Banks and Federal Savings Associations ................5 

II: Fair Access to Financial Services and Fair Treatment of National Bank 

and Federal Savings Association Customers ............................................................................7 

III: A Flexible Legal and Regulatory Framework That Enables 

National Banks and Federal Savings Associations to Provide a Full, 

Competitive Array of Financial Services Consistent With Statutory and 

Prudential Safety and Soundness Constraints ...........................................................................8 

IV: A Competent, Highly Motivated, and Diverse Workforce That Makes 

Effective Use of OCC Resources ..............................................................................................9 

Key Factors Affecting the OCC’s Achievement of Strategic Goals ............................................11 

Economic ..................................................................................................................................11 

Human Capital ..........................................................................................................................11 

Legislative .................................................................................................................................12 

Technology ...............................................................................................................................12 

Appendixes 

A: Strategic Management Process ............................................................................................14 

B: Relationship Between the OCC’s and Treasury Department’s Strategic Goals ..................15 

C: Program Evaluations ............................................................................................................16 

Comments or questions can be sent to the Office of the Comptroller of the Currency, 

Washington, DC 20219 or by e-mail to publicaffairs3@occ.treas.gov. 
 

 

 

 

 

 

 

 

 

Message From Acting Comptroller John Walsh 

I am proud to present the Office of the Comptroller of the Currency’s (OCC) Strategic Plan, 

Fiscal Years 2012–2016. 

The strategic plan describes the OCC’s strategic goals and objectives for carrying out its mission 

during the next five years. The plan provides a road map for how the OCC will ensure a safe and 

sound system of national banks and federal savings associations (collectively, banks); promote 

equal access to financial services and fair treatment of bank customers; maintain a flexible legal 

and regulatory framework that enables a strong, competitive system of banks; and field a 

competent, highly motivated, and diverse workforce. Equally important, the plan explains the 

internal and external programs that will be implemented to ensure that the OCC achieves results 

in a cost-effective manner. 

The OCC is engaged in 96 initiatives related to the implementation of the Dodd–Frank Wall 

Street Reform and Consumer Protection Act of 2010 (Dodd–Frank Act), which requires focus 

and diligence in the next several years. The OCC completed the orderly transfer of Office of 

Thrift Supervision staff and responsibilities in 2011, and the agency continues to serve on the 

Financial Stability Oversight Council. The OCC continues to work to reform capital and liquidity 

standards for financial institutions and collaborate with other regulators to identify and address 

irregularities in institutions’ foreclosure processes. 

The financial crisis of 2007–2009 serves as a stark reminder of how important the OCC’s 

mission is to the American people and to maintaining confidence in the U.S. banking sector. 

Looking ahead, the OCC will remain vigilant in the face of risks to the financial institutions it 

supervises as they navigate a business landscape significantly changed by post-crisis market 

developments and by new rules implementing the Dodd–Frank Act. 

John Walsh 

September 26, 2011 

The OCC’s Strategic Plan, Fiscal Years 2012–2016 1 
The OCC’s Strategic Plan, Fiscal Years 2012–2016 2 

The OCC Today 

The OCC is charged with assuring the safety and soundness of, and compliance with laws and 

regulations, fair access to financial services, and fair treatment of customers by, the institutions 

and other persons subject to its jurisdiction. Any national banking association, federal branch or 

agency of a foreign bank, or federal savings association is subject to OCC’s jurisdiction. 

Currently, the OCC supervises 2,108 banking institutions (1,415 national banks, 642 federal 

savings associations, and 51 federal branches of foreign banks in the United States) with total 

assets of $9.7 trillion. National bank and federal branch assets total $8.8 trillion and federal 

savings association assets total $907 billion. 

 

The OCC has about 3,800 employees in locations throughout the United States. The OCC has its 

headquarters in Washington, D.C., a data center in Maryland, and four district offices in 

Chicago, Dallas, Denver, and New York. The Customer Assistance Group is located in Houston. 

The OCC also operates field and satellite offices in cities throughout the United States, resident 

examiner teams in the largest banking companies, and an examining office in London, England. 

The OCC’s operations are primarily funded by semiannual assessments levied on banks. 

Condition of the Banking Industry 

Since 2007, the banking industry has operated in a challenging environment that included the 

longest and deepest recession since the Great Depression and major disruptions to financial 

markets. During the recession, system-wide credit problems produced a sharp drop in net income 

for banks, and many institutions became unprofitable. Commercial and residential real estate 

values plummeted. Unemployment jumped sharply, leaving millions of Americans looking for 

work. 

Banks are slowly recovering from the financial crisis. Aggregate industry net income is again 

positive, though below pre-recession levels, and 83 percent of OCC-supervised institutions were 

profitable as of June 2011. Credit problems have slowly abated, and charge-offs and noncurrent 

rates have fallen for most major loan categories. Still, those rates remain well above their longrun averages. The large drop in real estate property prices and continued sluggish growth in the 

labor markets suggest that banks will continue to face credit problems. Given this, the operating 

environment for the banking industry is likely to remain challenging for some time. 

Bank revenues fell during the recession, as loan growth turned negative. In the past year, large 

banks have seen revenues rebound; smaller banks have not improved as much, in part because of 

continued credit losses in some types of commercial real estate lending and a slow recovery in 

the demand for loans by small businesses. Revenues are likely to remain under pressure until 

conditions improve significantly. Regulatory changes are also expected to reduce revenue growth 

over the next several years for banks in all asset size categories. 
The OCC’s Strategic Plan, Fiscal Years 2012–2016 3 

Below-par economic growth, deleveraging by households, and continued weakness in property 

markets has resulted in negative loan growth at banks for nearly all major loan categories. Many 

larger firms have sizeable cash reserves that may tend to restrain commercial demand for bank 

loans, and even medium-size firms can now tap the bond markets for long-term, low-rate loans. 

Deleveraging by households and the public sector is likely to continue, which will directly and 

indirectly dampen loan growth for the foreseeable future. 

In the face of continuing credit problems, and without clear sources of revenue growth, profits at 

banks may remain anemic for some time. A less profitable banking system likely will be less 

resilient if confronted by stressful conditions in the future. 
The OCC’s Strategic Plan, Fiscal Years 2012–2016 4 

The OCC’s Mission and Vision 

Mission 

To assure the safety and soundness of, and compliance with laws and regulations, fair access to 

financial services, and fair treatment of customers by national banks and federal savings 

associations.

Vision 

The OCC seeks to assure a financial system in which national banks and federal savings 

associations soundly manage their risks, maintain the ability to compete effectively with other 

providers of financial services to meet the needs of their customers and communities for credit 

and financial services, comply with laws and regulations, and provide fair access to financial 

services and fair treatment of their customers. 
The OCC’s Strategic Plan, Fiscal Years 2012–2016 5 

Strategic Goals and Their Objectives and Strategies for 

Achieving the Goals 

The OCC has four strategic goals: 

I. A safe and sound system of national banks and federal savings associations 

II. Fair access to financial services and fair treatment of national bank and federal savings 

association customers 

III. A flexible legal and regulatory framework that enables national banks and federal savings 

associations to provide a full, competitive array of financial services consistent with 

statutory and prudential safety and soundness constraints 

IV. A competent, highly motivated, and diverse workforce that makes effective use of OCC 

resources 

Objectives and strategies are established for each strategic goal. Objectives further define the 

intended outcomes of each goal. Strategies are the means to align the OCC’s operational 

processes, skills, technologies, and resources to achieve its strategic goals and objectives. 

Strategic Goal I: A safe and sound system of national banks and federal 

savings associations 

Strategic Objective 1: The OCC anticipates, understands, addresses, and conveys risks to banks. 

The OCC seeks to fulfill this objective by 

A. ensuring risk-based supervision is properly executed and focused on systemic and bankspecific risks. 

B. identifying new products, services, and emerging risk areas, including those related to 

operational and technology-related vulnerabilities, and adjusting its supervisory strategies 

and activities, as appropriate. 

C. complying with the examination schedule requirements of the Federal Deposit Insurance 

Corporation Improvement Act (FDICIA). 

D. resolving problem banks in a timely fashion, effectively, and when possible, without loss to 

the deposit insurance fund. 

E. taking prompt and effective enforcement actions when warranted. 

F. conducting examinations to determine compliance with the Bank Secrecy Act, anti-money 

laundering, and the Uniting and Strengthening America by Providing Appropriate Tools 

Required to Intercept and Obstruct Terrorism Act (USA Patriot Act) requirements and 

enforcing anti-money laundering and anti-terrorism statutory and regulatory requirements. 
The OCC’s Strategic Plan, Fiscal Years 2012–2016 6 

G. ensuring banks comply with requirements of the Treasury Asset Relief Program (TARP), 

Temporary Liquidity Guarantee Program (TLGP), and Small Business Lending Fund (SBLF) 

Program. 

H. incorporating applicable lessons learned from the financial crisis, natural disasters, or 

emergencies and continuing to conduct periodic system-wide reviews and testing. 

I. providing an independent appellate process for banks. 

J. administering educational programs for banks and their leaders. 

Strategic Objective 2: The OCC cooperates with other U.S. and international financial 

supervisory authorities on common interests. The OCC seeks to fulfill this objective by 

A. working effectively with U.S. regulators and interagency groups to identify and address risks 

and emerging issues. The Comptroller serves on the board of directors of the Federal Deposit 

Insurance Corporation (FDIC) and the Federal Financial Institutions Examination Council 

(FFIEC), and is a member of the Financial Stability Oversight Council (FSOC). The OCC 

also works with the Basel Committee on Banking Supervision (Basel Committee), Financial 

Stability Board (FSB), the Joint Forum (JF), Senior Supervisors Group (SSG), Financial 

Banking and Infrastructure Information Committee (FBIIC), Bank Secrecy Act Advisory 

Group, and the National Interagency Bank Fraud Working Group. 

B. participating in joint supervisory programs, including the Shared National Credits (SNC) 

Program, Interagency Country Exposure Review Committee (ICERC), and the interagency 

examination program for multi-regional data processing servicers (MDPS). 

C. ensuring that Basel II and Basel III capital rule implementation embodies standards 

appropriate for the U.S. banking system. 

D. implementing existing and developing new coordination and collaboration agreements with 

the various federal regulators regarding supervisory activities performed in banks and with 

foreign regulators regarding supervisory activities and information exchange. 

Strategic Objective 3: Supervisory methods, analytical tools, and data analytics keep pace with 

industry changes and appropriately support the broader mission of the OCC. The OCC seeks to 

fulfill this objective by 

A. deploying supervisory technology solutions to achieve better data quality and provide userfriendly examiner access to key bank and industry information. 

B. developing analytical tools and reports that make effective use of data collected from 

institutions to foster superior decision making for supervisory operations and policy. 
The OCC’s Strategic Plan, Fiscal Years 2012–2016 7 

C. leveraging market-based and supervisory data and analyses to enhance supervision strategies 

and to provide an alternative, forward-looking perspective on emerging risks or pressure 

points systemically, across the industry, and for individual banking organizations. 

Strategic Goal II: Fair access to financial services and fair treatment of 

national bank and federal savings association customers 

Strategic Objective 1: All customers have fair access to financial services and are treated fairly. 

The OCC seeks to fulfill this objective by 

A. leading efforts to reform, and ensuring banks comply with, new mortgage servicing and 

foreclosure process standards. 

B. enhancing the OCC’s fair lending examinations for those banks where the OCC retains 

supervisory responsibility for fair lending activities. 

C. continuing to address unsound and predatory lending practices, customer privacy, 

information security, and identity theft. 

D. reinforcing the importance of fair and honest treatment of bank customers through 

appropriate supervisory and enforcement actions, customer complaints handled by the OCC’s 

Customer Assistance Group, and enhanced complaint-sharing between the OCC, the 

Consumer Financial Protection Bureau, and state agencies. 

Strategic Objective 2: Banks are involved in community and economic development activities. 

The OCC seeks to fulfill this objective by 

A. supporting the efforts of banks to engage in sound and successful community development 

activities. 

B. providing industry consultations on the effective implementation of the Community 

Reinvestment Act. 

C. participating as a member of the Financial Literacy and Education Commission and the board 

of NeighborWorks America. 

D. participating constructively in interagency community and economic development activities. 
The OCC’s Strategic Plan, Fiscal Years 2012–2016 8 

Strategic Goal III: A flexible legal and regulatory framework that enables 

national banks and federal savings associations to provide a full, competitive 

array of financial services consistent with statutory and prudential safety and 

soundness constraints 

Strategic Objective 1: Each OCC regulation is current, clearly written, and necessary for an 

effective supervisory process. The OCC seeks to fulfill this objective by 

A. implementing rulemakings required by the Dodd–Frank Act through successful collaboration 

and consultation with other federal agencies. 

B. reviewing and revising OCC regulations to further streamline and reflect new developments, 

including integration of OCC and former OTS regulations to embody common approaches. 

C. providing regulatory support for Basel II and Basel III capital rulemakings. 

Strategic Objective 2: The OCC supports national bank and federal savings association efforts to 

remain competitive, consistent with safety and soundness. The OCC seeks to fulfill this objective 

by 

A. supporting the continued recognition of the preemptive attributes of the national bank and 

federal savings association charters through appropriate opinions, regulations, and 

participation in litigation, when warranted. 

B. developing and modernizing attributes of national bank and federal savings association 

charters and the role and status of the national bank and federal savings association 

industries. 

C. enhancing communications with other federal agencies and state authorities to facilitate 

better coordination on issues affecting national banks and federal savings associations. 

D. ensuring that regulations applicable to national banks and federal savings associations 

facilitate their involvement in community and economic development activities. 

E. communicating attributes of the national bank and federal savings association charters and 

developments concerning national bank and federal savings association activities within and 

outside of the OCC. 

Strategic Objective 3: Licensing procedures are efficient and consistent with safety and 

soundness. The OCC seeks to fulfill this objective by 

A. reviewing licensing policies and procedures to provide clear and comprehensive guidance. 

B. implementing and maintaining processes for early screening of licensing applications and 

authorization requests. 
The OCC’s Strategic Plan, Fiscal Years 2012–2016 9 

C. deploying new or enhancing existing technology solutions that support effective licensing 

operations. 

D. integrating OCC and former OTS licensing standards and processes into a common 

approach. 

Strategic Goal IV: A competent, highly motivated, and diverse workforce that 

makes effective use of OCC resources 

Strategic Objective 1: The OCC maintains a competent, highly motivated, and diverse workforce 

in a fair and inclusive work environment. The OCC seeks to fulfill this objective by 

A. maintaining a comprehensive Human Capital Strategic Plan that includes the agency’s 

diversity goals and objectives. 

B. continuing to execute external hiring strategies to augment specialized skills to enhance the 

OCC’s supervision of complex bank activities and organizations. 

C. continuing to execute the OCC’s aggressive recruiting and comprehensive training strategy 

for new entry-level examiners. 

D. executing proactive initiatives focused on the retention of employees, including mentoring, 

employee feedback, employee outreach, incentives, and recognition programs. 

E. implementing and leveraging a metric-based training framework to develop a competent 

workforce, including the optimization of technology. 

F. creating a comprehensive leadership development program to support and enhance 

management succession. 

G. continuing various specialty skills programs to identify and develop examiners in the areas of 

asset management, bank information technology, capital markets, compliance, commercial 

lending, mortgage banking, retail lending, and operational risk. 

Strategic Objective 2: The OCC is an efficient, effective, and ethical organization. The OCC 

seeks to fulfill this objective by 

A. ensuring compliance with laws, regulations, and stewardship of its resources through 

program evaluations, quality assurance reviews, and an enterprise-wide quality management 

framework.

B. ensuring compliance with the rules, policies, and procedures for ethical conduct by its 

managers and employees. 

C. assuring reliable, secure, modern information technology systems and an environment that 

meet the OCC’s mission, goals, and objectives. 
The OCC’s Strategic Plan, Fiscal Years 2012–2016 10 

D. improving the effectiveness and integration of the current information technology 

governance structures, policies, processes, and procedures. 

E. deploying enterprise services to leverage technology and standard capabilities across the 

agency, with particular focus on information management initiatives, such as document, 

content, records, and knowledge management. 

F. ensuring existing technology that adds business value is properly maintained while 

re-engineering or implementing new systems, when appropriate. 

G. achieving increased efficiency and improved effectiveness by converting the information 

technology infrastructure from the mainframe platform to file servers. 

Strategic Objective 3: The OCC’s resource decisions and operations reflect sound financial, 

security, and risk management principles. The OCC seeks to fulfill this objective by 

A. implementing security controls commensurate with risk, to protect sensitive, private, and 

classified information. 

B. improving contingency planning for business continuity, including information technology 

recovery strategies, compliance with Homeland Security requirements, and crisis 

management strategies. 

C. improving the enterprise identity management program and ensuring compliance with 

Homeland Security requirements, Presidential directives, and e-Government initiatives. 

D. achieving reliable, accurate, and timely human and financial resources management 

information through enhanced internal controls. 

E. using best-practice benchmarks and risk assessments to guide resource allocation, 

management, and monitoring. 
The OCC’s Strategic Plan, Fiscal Years 2012–2016 11 

Key Factors Affecting the Achievement of Strategic Goals 

There are several factors that affect the achievement of the OCC’s strategic goals and program 

objectives. These factors fall into four broad categories: economic, human capital, legislative, 

and technology. 

Economic

Shifts in financial markets and the economy affect the risk profile of the banking industry, with 

implications for the direction of OCC supervisory strategy. The severe recession that began in 

late 2007 left in its wake sharp reductions in bank income, continuing credit problems, and 

declining loan demand. These problems may not be resolved quickly, and this calls for 

watchfulness and flexibility by regulators. 

Banks face an economic environment that will be difficult for some time. The slow pace of 

expected economic growth depresses both credit quality and revenue growth. Deleveraging by 

households, plus the corporate sector’s ability to fund operations from retained earnings, have 

added to downward pressure on loan demand, at the same time that new laws and regulations 

may reduce income from fees and other noninterest sources. The extended period of low interest 

rates continues to squeeze household incomes, affecting demand for mortgage and consumer 

loans, and margins at many banks. 

Financial markets stabilized after the financial crisis that began in 2008 but remain vulnerable to 

further shocks. Sovereign debt problems in Europe also continue to threaten a new wave of 

losses, which could jolt the markets again, as well as affecting large national banks with 

exposure to Europe. 

Human Capital 

There is no one factor more critical to the OCC’s overall success or its ability to accomplish its 

mission than its people. Acquiring, developing, and retaining a competent, highly motivated, and 

diverse workforce continues to be one of the OCC’s top priorities and is one of its four strategic 

goals. At the same time, and similar to the rest of the federal government, significant internal and 

external factors affect the OCC’s current and future workforce, challenging the agency’s ability 

to ensure that the right people are in the right positions at the right time. Human capital will 

remain a critically important issue for the OCC over the next five years. 

The OCC is facing retirements at unprecedented numbers and with it the loss of institutional 

knowledge and key leadership at all levels. The OCC expects the number of retirement eligibles, 

as well as the actual number of retirements, to increase over the next 10 years. By the end of 

fiscal year 2015, 32 percent of OCC’s current workforce will have either retired or attained 

eligibility for retirement. In certain areas, the impact will be greater. For example, 59 percent of 

our current Assistant Deputy Comptrollers will have retired or become eligible for retirement by 

the end of fiscal year 2015. At the same time, the OCC faces a competitive market for talent and 

a talent pool that is multigenerational and more diverse than ever before. This presents both 
The OCC’s Strategic Plan, Fiscal Years 2012–2016 12 

challenges and opportunities. Continued focus on building the agency’s pipeline of talent, 

particularly through its entry-level examiner hiring program, remains a priority. 

To remain a competitive, highly attractive employer, the OCC must continue to make diversity a 

priority. Support for diversity and ensuring an inclusive and respectful work environment is an 

important component of any successful organization. Given the changing demographics of the 

twenty-first–century workforce, diversity principles must be integrated into the OCC’s daily 

operations and decision making. The OCC has been long recognized as one of the best places to 

work in federal government, ranking in the top 10 among similarly sized federal agencies, 

especially in its support for diversity, training and development, and family-friendly policies and 

programs. A number of variables affect employee engagement and satisfaction—and thereby 

affect recruitment and retention—including flexible work environments, support for work–life 

balance and alignment of individual performance to the agency’s mission and strategic goals. 

Maintaining the OCC’s standing among smaller federal agencies as a top employer and its 

reputation within the industry as a premier financial regulator will be critical to attracting and 

retaining the necessary talent over the next five years. 

Succession planning, especially for key leadership and critical technical and expert positions, 

will be more important than ever. Capturing and making available the wealth of experience and 

expertise of the OCC’s current workforce through knowledge management and knowledge 

transfer is a business imperative. Ensuring that the OCC’s workforce, especially its missioncritical occupations of bank examiners, attorneys, and economists, is well trained, skilled, and 

capable of meeting the needs of the rapidly changing and extremely complex industry is 

essential. This is especially important given the recent expansion of OCC’s mission to include 

the federal savings association industry. This will require identifying critical skills and 

competencies; assessing gaps; and designing, developing, and delivering training and 

development programs to build or to improve those critical skills and competencies. 

Legislative 

 

The Dodd–Frank Act resulted in sweeping changes in laws governing the financial services 

industry. The legislation requires a myriad of rulemaking projects and supervisory initiatives by 

the OCC and other federal financial regulatory agencies to implement and adjust to those 

changes. The legislation will alter the ways in which banks do businesses in multiple respects: 

whether banks can conduct certain lines of business; how that business will be accomplished 

under changed circumstances; and, in some cases, how much they can charge for the products 

and services they are allowed to provide. Going forward, the OCC will look for opportunities to 

work with peer regulators, industry leaders, consumer advocates, and policymakers to advance 

appropriate legislative initiatives and reduce regulatory burden. 

Technology 

Responsive, stable, and secure information technology capabilities are essential to the OCC’s 

mission. To meet the broad demands of all internal and external stakeholders, the OCC must 

provide expertise, capabilities, and services in systems development and support. In addition, the 

agency must meet the needs for data, information, and knowledge management; collaboration 
The OCC’s Strategic Plan, Fiscal Years 2012–2016 13 

and information sharing; telecommunications and network support; enterprise-wide security 

operations; technical support; and incident management. The foundation of the OCC’s 

information technology service delivery approach comprises effective and reliable information 

technology infrastructure, information sources, and business solutions, reflecting a multi-year 

information technology strategy that will 

 provide fault-tolerant infrastructure for OCC business solutions and critical services, 

including e-mail. 

 create a single, integrated data architecture and provide end-user access to current, historic, 

and forecast information for banks. 

 provide access to business solutions, information, and services using reliable desktop, laptop, 

and hand-held devices that meet or exceed business performance requirements. 

 focus solution development resources and activities on data collection, data management, and 

data analysis and visualization, supporting bank supervision. 

 streamline the OCC’s application portfolio to remove redundant capabilities resulting from 

combined OCC–OTS operations, and retire end-of-lifecycle applications, reducing operating 

costs and reallocating resources to priority business requirements. 

 realign the OCC’s staff profile, training, and skills with its target architecture and 

information technology road map, creating an agile, responsive workforce to fulfill mission 

requirements. 

The OCC recognizes the threat that information security breaches represent to consumers, bank 

systems, and public confidence. The OCC regularly monitors bank compliance with laws and 

regulations, shares best practices, and takes enforcement actions to ensure compliance. In 

addition, the OCC ensures compliance with the Federal Information Security Management Act 

(FISMA) and executes initiatives to strengthen the internal security of sensitive information. 
The OCC’s Strategic Plan, Fiscal Years 2012–2016 14 

Appendixes 

 Appendix A: Strategic Management Process 

The OCC’s Executive Committee members discuss programmatic and management issues during 

its regular meetings and at the annual planning retreat. These discussions may lead to revising 

strategic initiatives or result in new short- or long-term initiatives. In many cases, these issues are 

assigned to the subcommittees of the Executive Committee (Committee on Bank Supervision; 

Financial Reform Oversight Group; Budget and Finance; Human Capital; Technology and 

Systems; and Enterprise Governance) to further define the initiatives and actions to be taken. 

Short-term actions can either modify the OCC’s current-year activities or serve as the basis for 

planning and budgeting for the subsequent year. Longer term initiatives are used to update the 

strategic plan. Generally, strategic discussions include the following: 

 An analysis of the condition of the banking industry, emerging issues and products in the 

financial services market, structural changes in the marketplace for financial services, 

legislative developments, an assessment of the competitiveness of national banks and federal 

savings associations in the evolving marketplace for financial services, and an evaluation of 

significant consumer financial services issues. 

 An evaluation of the existing risk profile and emerging risks in the banking industry, the 

large bank portfolio, and the midsize and community bank portfolio. 

 An assessment of internal strengths and weaknesses and a review of resource management 

issues, such as human capital, financial resources, technology, and fixed assets. 

 The integration of feedback from agency stakeholder groups and program evaluations. 

Coordinated by the OCC’s Ombudsman, the strategic goals, objectives, and strategies are 

reviewed, validated, and revised as necessary. The Ombudsman works through the various 

subcommittees of the Executive Committee or their designees to update or identify new goals, 

objectives, and strategies. The Comptroller and Executive Committee approve the final OCC 

Strategic Plan.

The goals, objectives, and strategies in the OCC Strategic Plan are further refined into activities 

to be accomplished annually. This is documented in the OCC Annual Performance Budget, 

functional operating plans, and ultimately employee performance plans. This process is the 

means of communicating the strategic direction and ensuring accountability for achieving goals 

and objectives throughout the organization. Annual performance goals and measures are 

established to monitor program accomplishments. 
The OCC’s Strategic Plan, Fiscal Years 2012–2016 15 

Appendix B: Relationship Between the OCC’s and Treasury Department’s 

Strategic Goals 

The following table depicts the relationship between the OCC’s strategic goals and measures and 

the Treasury Department’s strategic goals and high-priority performance goals.

Treasury Department’s 

Strategic Goals The OCC’s Strategic Goals The OCC’s Annual Performance Measures 

1. Repair and reform the 

financial system 

2. Enhance economic growth, 

competitiveness, and 

sustainability 

High-Priority Performance Goal 

Fiscal Years 2012 and 2013:

Increase small business access 

to capital 

4. Combat illicit financial activity 

to advance national security 

and the integrity of the financial 

system 

I. A safe and sound system of national 

banks and federal savings associations 

A. Percentage of national banks 

and federal savings associations 

that are categorized as well 

capitalized 

B. Percentage of national banks 

and federal savings associations 

with composite CAMELS rating 

of 1 or 2 

C. Rehabilitated national banks and 

federal savings associations as 

a percentage of the problem 

banks and federal savings 

associations one year ago 

(CAMELS 3, 4, or 5) 

II. Fair access to financial services and 

fair treatment of national bank and 

federal savings association customers 

Percentage of national banks and 

federal savings associations with 

consumer compliance rating of 1 or 2 

For institutions with assets over 

$10 billion these ratings reflect only 

those laws and regulations for which 

the OCC has enforcement and 

supervisory authority. 

III. A flexible legal and regulatory 

framework that enables national banks 

and federal savings associations to 

provide a full, competitive array of 

financial services consistent with 

statutory and prudential safety and 

soundness constraints 

Percentage of licensing applications 

and notices completed within 

established time frames 

5. Foster a prudent use of 

taxpayer resources to operate 

the federal government 

IV. A competent, highly motivated, and 

diverse workforce that makes effective 

use of OCC resources 

Total OCC costs relative to every 

$100,000 in assets regulated 
The OCC’s Strategic Plan, Fiscal Years 2012–2016 16 

Appendix C: Program Evaluations 

Both internal and external program evaluations are used to assess whether OCC programs are 

achieving their intended results in a cost-effective manner. The results of these reviews are used 

to revise existing or to identify new program objectives and strategies in the OCC Strategic Plan.

Generally, the schedule for internal program evaluations is developed annually, with additional 

evaluations initiated as warranted. 

Internal Program Evaluations 

The OCC’s formal program evaluation efforts include 

 Departmental Quality Management programs. 

 the Self-Assessment for Managers Questionnaire. 

 the Financial Reporting Internal Controls Program. 

 Office of the Ombudsman programs. 

 the Licensing Customer Satisfaction Feedback Program. 

Departmental Quality Management Programs. All Executive Committee–level department 

heads established quality management programs in their respective areas of responsibility and 

annually certify that 

 programs achieve their intended results. 

 resources align with the mission and strategic plan. 

 resources are protected from waste, fraud, and abuse. 

 laws and regulations are followed. 

 reliable and timely management information systems support decisions. 

Self-Assessment for Managers Questionnaire. The annual questionnaire reminds managers of 

established OCC operating policies and secures a self-assessment of their level of compliance 

with those policies. 

Financial Reporting Internal Controls Program. The Financial Management Department 

oversees the documentation of key processes of financial reporting and testing of the related 

internal controls. The results of these reviews enhance internal controls and support the 

Comptroller’s assurance statement required by the Office of Management and Budget (OMB) 

Circular A-123, Appendix A. Assessment of the effectiveness of internal controls over financial 

reporting is completed annually. 

Office of the Ombudsman Programs. The Ombudsman provides program-level information for 

the strategic management process through its administration of the bank appeals process, the 

customer assistance program, and ongoing examination questionnaires provided to bank chief 

executive officers for feedback on the quality of OCC supervision. Program evaluation activities 

are continual. 
The OCC’s Strategic Plan, Fiscal Years 2012–2016 17 

The Enterprise Governance Division reports to the Ombudsman and is subject to the oversight of 

the Enterprise Governance Subcommittee. The division is responsible for administering a quality 

management framework for the OCC. For each OCC department-level unit, Enterprise 

Governance 

 documents the department’s goals and objectives and related measures. 

 documents the processes and systems the department uses to measure and monitor 

achievement of the goals and objectives. 

 verifies that structured and unstructured quality management activities are completed. 

 documents the department’s assessment as to whether each goal and objective was 

effectively achieved. 

The Enterprise Governance program supports the annual departmental certifications and the 

Comptroller’s annual assurance statement. 

Licensing Customer Satisfaction Feedback Program. Each recipient of an OCC corporate 

decision is surveyed to obtain customer service feedback regarding the timeliness of application 

processing, staff professionalism, courtesy, knowledge of the licensing process, availability of 

electronic filing, and the quality of written OCC guidance. Program evaluation activities are 

continual. 

External Program Evaluations 

In addition to the OCC’s ongoing internal program evaluation efforts, the OCC receives 

program-level feedback from the following external sources: 

 Office of the Inspector General (OIG), Department of the Treasury 

 Office of the Special Inspector General for the Troubled Asset Relief Program (SIGTARP), 

Department of the Treasury 

 U.S. Government Accountability Office (GAO) 

 Independent certified public accountant 

Office of the Inspector General. The OIG conducts reviews of OCC operations every year. The 

results from the OIG program and compliance audits provide useful input into the OCC strategic 

management process. 

Office of the Special Inspector General for the Troubled Asset Relief Program. SIGTARP 

was established by the Emergency Economic Stabilization Act of 2008 (EESA). Under EESA, 

the Special Inspector General conducts, supervises, and coordinates audits and investigations of 

the purchase, management, and sale of assets under the Troubled Asset Relief Program (TARP). 

U.S. Government Accountability Office. The GAO conducts targeted reviews of OCC 

regulation and supervision of banks. 
The OCC’s Strategic Plan, Fiscal Years 2012–2016 18 

Independent certified public accountant. Every year, the OCC commissions the services of an 

accounting firm to conduct a financial statement opinion audit and to provide senior management 

with conclusions on the effectiveness of the OCC’s program of financial controls.