Consult the following sources of information (if applicable and available), review the types of CIFs offered by the bank, and gain an understanding of previous supervisory risk assessments:

• Annual CIF financial reports;

• OCC information databases;

• Previous reports of examinations and management letters covering CIFs and investment management activities, analyses, related board and management responses, and work papers;

• The asset management profile;

• OCC correspondence files;

• Call Report Schedule RC-T;

• Supervisory reports issued by other functional regulators, particularly if the CIFs are advised by an affiliated registered investment adviser or registered separately identifiable department or division (SIDD) of the bank; and

• CIF monitoring reports from the board, committees, business lines, risk management groups, compliance, legal, and audit functions.

Discuss the following with managers responsible for CIFs:

• Significant risk issues and management strategies including, when CIFs and affiliated investment companies are both offered, the objectives and strategies for using one fund rather than the other;

• Significant changes in strategies, products, services, and distribution channels;

• Significant changes in organization, policies, controls, and information systems; and

• External factors that are affecting services, particularly the use of third-party vendors and automated trading platforms.

Develop a preliminary risk assessment and discuss it with the asset management EIC and/or the bank EIC for perspective and examination planning coordination. Consider the following:

• Previous examination conclusions and recommendations;

• Internal risk and control assessments;

• Strategic and business plans;

• Introduction of new funds or significant modifications to existing funds; and

• Changes in organization, policies, procedures, controls, and information systems.

Reconfirm and finalize the timing, scope, and work plans for examination activity to be completed during the supervisory cycle. Decisions concerning the use of expanded procedures should be clearly documented.

If applicable, prepare and submit a revised examination planning memorandum for approval by the asset management EIC that includes the following information:

• Examination activity objectives including a description of the types of CIFs or fund processes to be reviewed.

• The types (on-site and quarterly monitoring), schedules, and projected workdays of the examination activity.

• The scope of examination procedures to be completed, including the use of expanded procedures and risk-oriented sampling guidelines. The memorandum should address the amount of testing or direct verification that may be necessary. The scope of examination activity and the selected procedures should be consistent with the risk assessment and should focus on higher risk activities.

• The examiner resources necessary to complete the activities.

• The types of communication planned, such as meetings and final written products.

Finalize the examination’s work assignments.

Discuss the examination plan with appropriate bank personnel and make suitable arrangements for on-site accommodations and additional information requests.

If applicable, contact each examination team member and provide necessary details concerning examination assignments and schedules.

The “Examination Planning and Control,” “Large Bank Supervision,” “Community Bank Supervision,” and “Asset Management” booklets of the Comptroller’s Handbook contain additional guidance on and procedures for examination planning activities.