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Financial Services Law Insights and Observations

OCC Updates Floor Plan Lending Guidance

Examination OCC Auto Finance Agency Rule-Making & Guidance

Consumer Finance

On October 27, the OCC issued an updated Floor Plan Lending booklet of the Comptroller’s Handbook. The revised booklet (i) summarizes the basics of floor plan lending for examiners, including a description of indirect dealer lending and the regulatory and legal foundation for floor plan lending; (ii)  provides banks with sound risk management practices and describes regulatory risk rating guidelines; and (iii) includes an expanded examination procedures section with examples of risk rating cases and factors for determining the quantity of credit risk and the quality of credit risk management. The updated booklet replaces a similarly titled booklet issued in March 1990, as well as section 216 of “Floor Plan and Indirect Lending” issued in January 1994 as part of the former Office of Thrift Supervision’s Examination Handbook.