All banks must employ sound fundamental principals which identify risks, establish controls, and provide for monitoring systems for consigned items and other customer services. In many cases, banks may choose to establish and communicate these sound principles in writing. The OCC fully endorses putting these principles in writing to better ensure effective communications throughout the bank. If, however, management follows sound fundamental principles and governs the risk in these areas, the OCC does not require a bank to have a written policy for consigned items and other customer services. If management does not practice sound principles, however, the OCC may require management to establish written policies in order to formally communicate risk parameters and controls to the appropriate levels of the bank.
Sound fundamental principles for consigned items and other customer services include proper internal controls, operating procedures and safeguards, and audit coverage. These principles are explained throughout this booklet.