Product Updates March 2016

New and Revised Policy Templates for March 2016

Credit Card Policy Template – NEW!

This new product was developed in response to client requests and OCC Bulletin 2015-41 issued on 11/04/15 that announced a revised Credit Card Lending Booklet which incorporates statutes and regulations, guidance, examination procedures, and standards for assessing and managing the risks associated with credit card lending activities.  The revised booklet:

  • Rescinds the following advisory letters, which are largely superseded by the 2009 Credit Card Accountability Responsibility and Disclosure Act (CARD Act) and its implementing regulations in Regulation Z:
    • Advisory Letter 2004-4, “Secured Credit Cards” (April 28, 2004)
    • Advisory Letter 2004-10, “Credit Card Practices” (September 14, 2004)
  • Makes the following applicable to FSAs:
    • OCC Bulletin 1997-24, “Credit Scoring Models: Examination Guidance” (May 20, 1997)
  • Provides updated guidance to examiners on assessing the quantity of risk associated with credit card lending and the quality of credit card lending risk management.
  • Addresses the CARD Act, which further amended the Truth in Lending Act.

Country Risk Management Program Policy Template

This product was revised in response to OCC Bulletin 2016-4 issued on 02/12/16 that announced a revised Country Risk Management Booklet that includes guidance related to board and management oversight, policies and procedures, country exposure reporting system, country risk analysis process, country risk ratings, country exposure limits, monitoring country conditions, stress testing and integrated scenario planning, and independent risk management, internal controls, and audit.  This booklet

  • Provides updated and expanded guidance and examination procedures to examiners concerning country risk management.
  • Reflects lessons learned from the financial crisis of 2008 and the European banking and debt crises.
  • Updates the risks associated with international activities by providing more in-depth discussion of the effects of country risk, cross-border risk, and sovereign risk on the OCC’s eight risk categories (credit, interest rate, liquidity, price, operational, compliance, strategic, and reputation).
  • Adds an internal control questionnaire and a glossary.
  • Expands the sample request letter.
  • Addresses the risk management of third-party providers.

The issuance of this booklet makes OCC Bulletin 2002-10, “Country Risk: Sound Risk Management Practices,” applicable to federal savings associations.