OCC Staffing Plans

Why doesn’t the OCC publish a staffing plan so that employees know where openings and opportunities are in the districts and large banks?

Almost nobody in the OCC understands how staffing plans are currently determined.  However, for those who have been with agency 20 plus years, you will probably remember a time when the OCC had a clear and transparent staffing plan.  Management based staffing plans on Eight Hierarchies of Risk and the workdays that were associated with each.

The Eight Hierarchies were:

1. Systemic Risk,
2. Large Bank Supervision,
3. ICERC and SNC,
4. Regional Bank Supervision,
5. Camels 3, 4 and 5 rated community banks with assets in excess of $100MM, 
6. Camels 1 & 2 rated community banks with asset in excess of $100MM,
7. Camel 3, 4 and 5 rated community banks with assets of less than $100 million, and
8. 1 and 2 rated community banks with assets of less than $100 million.

Management plugged the total required workdays into each of the 8 hierarchies on a Field Office by Field Office basis.  Within each hierarchy, there were built-in assumptions about the level of examination staff needed to fulfill the requirements.  For example, in hierarchy 8 banks, there was an assumption that commissioned examiners would perform 25% of the work and non-commissioned examiners would perform the other 75%.  

They further broke down the commissioned-level work by three grades of commissioned examiners (at the time CP-6, CP-7 and CP-10).  Obviously, as you worked your way up through the hierarchies, the complexity of the necessary work required greater skill level reflected in the higher grades.  Another key assumption to these staffing plans was that for bank supervision a full time equivalent (FTE) employee was the equivalent of 150 workdays, acknowledging the need for leave, training, travel, administrative time, etc.).  150 workdays was approximately two-thirds of a full FTE.  Management then published these staffing plans so that everyone was aware of where the opportunities and openings were within the district.  It was a fairly straightforward process that was transparent and clear to most employees.

What are the implications for today?

As the OCC continues to look at pay banding, NTEU suggests that management develop highly objective criteria to define the staffing levels needed in both LBS and MCBS.  We need position descriptions that include clearly-defined and objective criteria in both lines of businesses.  Currently, pay level position descriptions in LBS and MCBS are the same even though the work of the incumbents is very different.  In addition, position descriptions and the methodology used to determine staffing plans should be transparent and shared with employees.  While NTEU is not necessarily suggesting a return to the 8 hierarchies of risk, we are suggesting that clear and objective criteria helps remove skepticism about favoritism that currently permeates the government job force, including the OCC. 

Succession Planning (or Lack Thereof)

We received this comment from one of our readers:

“I wanted to talk to you about OCC succession planning.  There isn't any.  And I think this is a big issue and I am very frustrated.  I have told my LB EIC and the Deputy Comptroller that I am retiring at the end of 2010. That date is pretty firm, and there are a number of reasons why I have announced it, ranging from me feeling like I should give sufficient notice so the team is prepared and whomever replaces me can come on board in time to get an understanding of the bank, obtain continuity, etc.  Sort of a best practice, don't you think?”

While this is not necessarily a “union issue,” it is a big OCC issue and many employees are expressing similar concerns.  Retirement is a big decision and for many people, talking about it and setting a date/goal is a good way to help them prepare.  Most employees have developed close ties to their coworkers and strong loyalty to the organization and do not want to leave without ensuring a smooth transition is in place for their coworkers and successor(s).  Many people left in 2009, and many more are eligible during the next three years.    

The OCC seems to have recently developed a mantra: “it is your job to find your replacement.”  Retiring OCC employees generally inform individuals whom they believe might be interested or are qualified for their position.  However, to expect retiring employees to find their replacement is somewhat unrealistic.  While retiring employees should give sufficient notice that they are leaving, it is management’s job to ensure that a succession plan is in place.  

Nevertheless, many OCC employees believe that no one in management is addressing succession planning for the many examiners expected to retire in 2010 and beyond.  The bankers are very concerned, especially in large banks, because of the steep learning curve that is necessary to understand the bank, learn its systems, and establish working relationships in that interim period.   

So what is a solution?  When it is evident that an OCC employee is nearing retirement, management should post for that position.  "Evident" can be relative and it would not be unreasonable to want some assurances a retirement date range is reasonably fixed.  While this will cause some staffing overlap, in the long term it allows for a smoother transition and less interruption to the team and the bank.  Another option would be an Expression of Interest for interim work or an apprentice role for a set period of time. 

Management so far has been steadfast in not posting positions until the vacancy actually occurs.  When this happens, there is always a gap that the rest of the team must fill, or where they get someone to work for a period of time, or that they “draft” someone to the team (i.e. involuntary transfer).  There seems to be ample precedent on the involuntary transfers.  This is not an effective succession planning process.  Providing for continuity of supervision is simply the right thing to do.  We would expect that the executive management of the OCC would be working with EICs, team leads, and others in supervisory positions to steer people to these opened or soon to be opened positions.  However, we hear nothing of such emphasis or concern or action.

As a sidebar, many OCC employees are also perplexed as to why executive management feels that large banks only need to be staffed at 70 - 80% of strategy workdays.  It is interesting that that the agency is spending so much time and money on WISDM, STARS, and other user non-'friendly/helpful/functional' systems and not enough on the agency's "primary resource": our people.

Succession planning equals success!   

As always we want to hear your feedback, good, bad or indifferent. Write us at this website.

A seat at the table, professionalism and fair and equitable treatment of employees…union values that you can count on (through out the year)!!!