Collective Investment Funds

Examination Conclusions

Objective: To consolidate the conclusions and recommendations from the CIF examination activities into final conclusions on the quantity of risk and quality of risk management.

1.

Obtain conclusion memoranda and other risk assessment products from completed examination procedures.

2.

Discuss the individual examination findings with the responsible examiners and ensure that conclusions and recommendations are accurate, supported, and appropriately communicated.

3.

Determine and document the recommended rating for the “compliance” element based on the factors listed in the Uniform Interagency Trust Rating System (UITRS).

4.

Finalize quantity of risk and quality of risk management conclusions for input into the following, when applicable:

  • Core knowledge database.

  • Core assessment standards (CAS).

  • Risk assessment system (RAS).

  • Uniform Interagency Trust Rating System (UITRS).

  • CAMELS.

  • Report of examination.

  • Asset management profile (AMP).

Objective: To communicate examination findings and initiate corrective action, if applicable.

1.

Provide the EIC the following information, when applicable:

  • Examination summary comments for the core assessment.

  • Comments applicable to the RAS.

  • UITRS ratings recommendations.

  • Draft report of examination comments.

  • Matters requiring attention (MRA).

  • Violations of law and regulation and corrective action.

  • Other recommendations provided to bank management.

2.

Discuss examination findings with the EIC and adjust findings and recommendations as needed. If the UITRS compliance rating is 3 or worse or if the level of any risk factor is moderate and increasing or high because of the impact of collective investment fund activities, contact the supervisory office before providing draft examination conclusions or report comments and before conducting the exit meeting with management.

3.

Hold an exit meeting with appropriate CIF committees and/or other risk managers to communicate examination conclusions and obtain commitments for corrective action, if applicable. Allow management time before the meeting to review draft examination conclusions and report comments.

4.

Prepare final comments for the report of examination as requested by the EIC. Perform a final check to determine whether comments

  • Meet OCC report of examination guidelines.

  • Support assigned UITRS ratings.

  • Contain accurate violation citations.

5.

If there are MRA comments, enter them in the OCC’s electronic information system. Ensure that the comments are consistent with MRA content requirements.

6.

Prepare appropriate comments for the CIF examination conclusion memorandum. Supplement the memorandum’s comments, when appropriate, to include the following:

  • The objectives and scope of completed supervisory activities;

  • Reasons for changes in the supervisory strategy, if applicable;

  • Overall conclusions, recommendations for corrective action, and management’s commitments and time frames; and

  • Comments on any recommended administrative actions, enforcement actions, and civil money penalty referrals.

7.

Update applicable sections of the OCC’s electronic information system.

8.

Prepare an updated supervisory strategy for CIF administration and provide it to the asset management EIC for review and approval.

9.

Prepare a memorandum or update work programs with any information that will facilitate future examinations.

10.

Organize and reference work papers in accordance with OCC guidelines.

11.

Complete and distribute assignment evaluations for assisting examiners, as appropriate.

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