OCC Updates Booklet in its Handbook Concerning Collective Investment Funds

The OCC issued a revised and updated booklet (the “Revised Booklet") concerning collective investment funds (“CIFs”).  The Revised Booklet is part of the OCC’s “Comptroller’s Handbook.”  The Revised Booklet (which updates the OCC’s prior 2005 guidance) describes and discusses various aspects of CIFs and provides guidance regarding risk management of CIFs.

The Revised Booklet contains updated discussions of, among other topics, investment risk management and valuation of CIFs, securities lending, audit and financial reports of CIFs and Board of Directors and senior management responsibilities for oversight of risk management of CIFs.  In the Revised Booklet, the OCC cautions that, in reviewing risk management of CIFs, the OCC will closely scrutinize a bank’s arrangements with third-party vendors.

In conjunction with the OCC’s issuance of the Revised Booklet, the OCC rescinded its 1990 Banking Circular 247 “Application of Securities Laws to Common Trust Funds.”

IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. tax advice contained in this informational piece (including any attachments) is not intended or written to be used, and may not be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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