OCC Updates Asset Management Booklet

Troutman Pepper

On June 22, the Office of the Comptroller of the Currency (OCC) released Version 1.0 of its Asset Management booklet, which provides an overview of sound risk management processes for bank asset management. The OCC will apply this updated booklet to the supervision of community banks engaged in asset management activities.

Version 1.0 is a targeted update that replaces the previous edition from 2000, and expands the scope of fiduciary audit requirements to:

  • “Clarify the meaning of “significant fiduciary activities” and the OCC’s expectations regarding the frequency of audits under a continuous audit system;
  • Incorporate guidance on audit oversight, requirements, risk assessment, planning, independence, and reporting expectations;
  • Add language from 12 C.F.R. § 150 that applies to federal savings associations;
  • Outline audit committee membership requirements and responsibilities;
  • Clarify determination of audit scope and coverage; and
  • Define a robust, well-documented, risk assessment that supports significant fiduciary activities and development of a meaningful audit plan.”

The OCC plans to publish a more extensive update to the booklet at a later date. We will continue to monitor OCC releases and guidance for further changes to this booklet.

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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