EC - 264
EXAMINING ISSUANCE
Comptroller of the Currency
Administrator of National Banks
Type:  Examining Circular
Subject:  Data Collection for Small Business Loan Documentation

TO:  Deputy Comptrollers, District Administrators, Department and Division
     Heads, and All Examining Personnel

PURPOSE

This issuance establishes a program to collect data on loans that banks
identify for exemption from unnecessary documentation under the
Interagency Policy Statement on Documentation for Loans to Small- and
Medium-sized Businesses and Farms.

REFERENCES

This issuance should be read in conjunction with Banking Bulletin 93-18
(Interagency Policy on Small Business Loan Documentation) dated April 2,
1993 and SMS Technical Bulletin 93-1 (attached).

BACKGROUND

The Interagency Policy Statement allows highly rated and well- or
adequately capitalized institutions to identify an "exempt portion" of
their small- and medium-sized business and farm loan portfolios. Those
loans will be evaluated solely on performance and will be exempt from
examiner criticism of documentation. The OCC must monitor how qualifying
institutions implement the provisions of the Interagency Policy Statement
and how those institutions and the "exempt portion" loans perform.

This issuance establishes a monitoring program that will collect data
during examinations and record it in the Supervisory Monitoring System
(SMS). Examiners should enter the following data on the Asset Statistics
record in the Supervisory Data application of SMS:

o Number of loans in the "exempt portion,"

o Total dollar amount of loans in the "exempt portion," and

o Total dollar amount of loans in the "exempt portion" that are past due.

DATA COLLECTION REQUIREMENTS

Effective immediately, the OCC will commence collecting this data on the
"exempt portion" of the small- and medium-sized business and farm loan
portfolios. Examiners should collect the data during the next examination
or periodic financial review if it is readily available. The data must be
updated at each subsequent examination, but no less frequently than once
each year at the full scope, on-site examination.

ORIGINATING OFFICE

For additional guidance on collecting this data, contact the Office of the
Chief National Bank Examiner in Washington, D.C. (202) 874-5170.


Donald G. Coonley
Chief National Bank Examiner

Attachment

Date:  April 29, 1993