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Financial Services Law Insights and Observations

OCC updates Comptroller’s Handbook booklets, addresses trade finance and services activities

Agency Rule-Making & Guidance OCC Comptroller's Handbook Examination Bank Supervision

Agency Rule-Making & Guidance

On October 15, the OCC issued Bulletin 2018-38, which updates, among other things, the “Trade Finance and Services” booklet of the Comptroller’s Handbook previously issued in April 2015. The booklet provides guidance for OCC examiners to use in connection with the examination and supervision of national banks and federal savings associations that engage in international trade finance and services activites, including “letters of credit, guarantees, acceptances, open account financing, other specialized trade financing, financial supply chain solutions, prepayment, advising, trade collections, bank-to-bank reimbursement services, insourcing/outsourcing trade processing, and hedging services.”

The updated booklet (i) incorporates references to relevant OCC issuances published since April 2015; (ii) reflects the integration of federal savings associations into certain regulations; and (iii) makes “clarifying edits regarding supervisory guidance, sound risk management practices, legal language, or the roles of the bank’s board or management.”

Bulletin 2018-38 also updates the “Agricultural Lending” and “Oil and Gas Exploration and Production Lending” booklets and rescinds previously issued corresponding bulletins.