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OCC BULLETIN 2014-11
To: Chief Executive Officers of All National Banks and Federal Savings Associations, Department and Division Heads, All Examining Personnel, and Other Interested Parties

Description: New Comptroller's Handbook Booklet and Rescissions

Summary

The Office of the Comptroller of the Currency (OCC) issued today the “Asset-Based Lending” booklet, which is new to the Comptroller’s Handbook.

Highlights

The “Asset-Based Lending” booklet

  • provides risk management guidance to examiners and bankers for asset-based lending (ABL) activities.
  • expands and replaces prior ABL guidance.
  • presents risk-rating examples.

Note for Community Banks

This booklet applies to all national banks and federal savings associations engaged in ABL activities.

Background

This booklet expands the ABL examination fundamentals discussed in the “Accounts Receivable and Inventory Financing” booklet of the Comptroller’s Handbook, issued in March 2000, and replaces ABL guidance in section 214, “Other Commercial Lending,” issued in October 2009 as part of the Office of Thrift Supervision’s (OTS) Examination Handbook.

The OCC’s “Asset-Based Lending” booklet provides guidance to examiners and bankers regarding ABL activities and risks, prudent credit risk management and underwriting expectations, credit administration, and credit risk rating. Risk-based expanded examination procedures are provided to guide ABL examinations. Expanded topics include ABL structures, credit analysis, evaluating borrower liquidity, establishing a borrowing base and prudent advance rates, collateral controls and monitoring systems, and credit risk rating considerations. The booklet also includes transaction examples to guide examiners and bankers in the assessment of credit risk.

With the issuance of this booklet, the ABL guidance on pages 16–20 of section 214 of the OTS Examination Handbook is rescinded.

For further information, contact Grant Wilson, Director for Commercial Credit Risk, at (202) 649-6432.

 

John C. Lyons Jr.
Senior Deputy Comptroller and Chief National Bank Examiner

 

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