OCC Updates Comptroller Handbook on Installment Lending and Country Risk Management

The Office of the Comptroller of the Currency ("OCC") updated and replaced the March 1990 version of the "Installment Lending" booklet, and the March 2008 version of the "Country Risk Management" booklet, contained in the Comptroller's Handbook.

Revisions to the Installment Lending booklet include:

  • The rescinding of OCC Bulletin 2004-59, "Retail Lending: Interim Examination Procedures."

  • Updated guidance for examiners on assessing the quantity of risk associated with installment lending activities, and additional guidance for assessing the quality of installment lending risk management.

  • Updated guidance for examiners on the administration of installment lending practices and the controls and processes necessary to manage the associated risks effectively. These processes include underwriting or account eligibility criteria, charge-off, risk management and control systems, and third-party management.

Revisions to the "Country Risk Management" booklet include:

  • Updated and expanded guidance and examination procedures concerning country risk management.

  • The inclusion of lessons learned from the financial crisis of 2008 and the European banking and debt crises.

  • Updated guidance on risks associated with international activities that provides a more in-depth discussion of the effects of country risk, cross-border risk and sovereign risk within the OCC's eight risk categories (credit, interest rate, liquidity, price, operational, compliance, strategic and reputation).

  • An additional internal control questionnaire and glossary.

  • An expanded sample request letter.

  • A description of the risk management of third-party providers.

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