1. Provide EIC with a brief conclusion regarding:

The adequacy of the bank’s policies, procedures, and internal controls.

Violations of laws, rulings, and regulations.

Recommended corrective action when policies or practices are deficient.

The quantity of risk and the quality of risk management in all areas reviewed.

2. Determine the impact on the aggregate and direction of risk assessments for any applicable risks identified by performing the above procedures. Examiners should refer to guidance provided under the OCC’s large and community bank risk assessment programs.

Risk Categories: Transaction, Compliance, Reputation

Risk Conclusions: High, Moderate, or Low

Risk Direction: Increasing, Stable, or Decreasing

3. Discuss findings with management including:

The adequacy of the bank’s policies, procedures, and internal controls.

Violations of laws, rulings, and regulations.

Recommended corrective action when policies or practices are deficient.

The quantity of risk and the quality of risk management in all areas reviewed.

The impact on the aggregate and direction of risk assessments for applicable risks.

As appropriate, prepare a brief consigned items and other customer services comment for inclusion in the report of examination.

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

Update the OCC database.

Organize and reference working papers in accordance with OCC guidance.