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Financial Services Law Insights and Observations

OCC Updates Comptroller’s Handbook, Issues New Guidance for Evaluating Retail Lending Risk Management

Agency Rule-Making & Guidance OCC Risk Management

Agency Rule-Making & Guidance

On April 12, the OCC issued Bulletin OCC 2017-15 announcing its new booklet, “Retail Lending,” which discusses retail lending risks and measures for evaluating retail credit risk management activities. The booklet, part of the Comptroller’s Handbook, applies to “examinations of all institutions engaged in retail lending” and supplements the following core assessment sections: “Large Bank Supervision,” “Community Bank Supervision,” and “Federal Branches and Agency Supervision.” According to the Bulletin, Examiners should reference this booklet when review beyond the core assessment is appropriate because the specific products, services, or activities “have a material impact on the risk profile and financial condition” of banks. The new booklet describes (i) “characteristics of an effective retail credit risk management framework”; (ii) “criteria examiners should consider when evaluating retail credit originations, account management, collections, and portfolio management activities and processes”; and (iii) “objectives of control functions commonly used in a retail lending business to measure performance, make decisions about risk, and assess the effectiveness of processes and personnel.”