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Date: May 4, 2010
To: Chief Executive Officers of All National Banks, Department and Division Heads, All Examining Personnel, and Other Interested Parties
Description: Final Guidance: Interagency Guidance on Correspondent Concentration Risks
The guidance attached to this bulletin continues to apply to federal savings associations.
The Office of the Comptroller of the Currency, Federal Reserve Board, Federal Deposit Insurance Corporation, and the Office of Thrift Supervision (collectively, the agencies) are issuing the final Interagency Guidance on Correspondent Concentration Risks (guidance). This guidance outlines the agencies’ expectations for financial institutions to identify, monitor, and manage credit and funding concentrations to other institutions on a standalone and organization-wide basis, and to take into account exposures to the correspondents’ affiliates. Institutions also should be aware of their affiliates’ exposures to correspondents as well as the correspondents’ subsidiaries and affiliates. In addition, the guidance addresses the agencies’ expectations for financial institutions to perform appropriate due diligence on all credit exposures to and funding transactions with other financial institutions.
This guidance does not supplant or amend applicable regulations such as the Federal Reserve Board’s Limitations on Interbank Liabilities (Regulation F). It clarifies that financial institutions may need to take actions beyond the minimum requirements established in Regulation F to identify, monitor, and manage correspondent concentration risks, especially when rapid changes exist in market conditions or in a correspondent’s financial condition, in order to maintain risk management practices consistent with safe and sound operations.