The Office of the Comptroller Provides Updated Guidance for Risk Assessment System

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On December 3, 2015, the Office of the Comptroller of the Currency (“OCC”) provided updated guidance for its risk assessment system (“RAS”). The guidance (i) clarifies the relationship between RAS and the Uniform Financial Institutions Rating System (“CAMELS”), (ii) revises the definition of banking risk, (iii) expands the “quality of risk management” assessment, and (iv) expands strategic and reputation risk assessments. These updates affect the following booklets of the Comptroller’s Handbook: “Bank Supervision Process,” “Community Bank Supervision,” “Federal Branches and Agencies Supervision,” and “Large Bank Supervision.” Press Release.

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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