Objective: To communicate findings and initiate corrective action when policies, practices, procedures, or internal controls are deficient or when violations of law, rulings, or regulations occur.

1. Prepare a summary memorandum to the EIC detailing the results of the evaluation of the bank’s country risk management process. Draft conclusions on:

   • The extent to which the bank’s international operations affect the aggregate level of risk in the bank.

   • The quality of the bank’s country risk management process.

2. Also address in the summary memorandum:

   • Any concerns about the level and/or trend in the direction of country risk in countries in which the bank has significant exposure.

   • Appropriateness of strategic and business plans for the bank’s international activities.

   • Adequacy of adherence to policies and country exposure limits.

   • Adequacy of systems for analyzing country risk and assigning risk-ratings.

   • Adequacy of country risk control functions, including MIS and audit.

   • Compliance with applicable laws, rules, and regulations.

   • Recommended corrective action for deficient policies, procedures, practices, or other concerns.

   • Other matters of significance.

3. For any issues of concern identified when performing the country risk management procedures, determine their impact on the bank’s aggregate risk and the direction of its risks. Examiners should refer to guidance provided under the OCC’s large and community bank risk assessment programs.

4. Discuss examination findings and conclusions with the EIC. If necessary, compose “Matters Requiring Attention” (MRA) for the country risk management examination. MRAs should cover practices that:

   • Deviate from sound, fundamental principles and are likely to result in financial deterioration or increased risk if not addressed.

   • Result in substantive noncompliance with laws.

5. MRAs should discuss:

   • Causes of the problem.

   • Consequences of inaction.

   • Management’s commitment to corrective action.

   • The time frame for corrective action and person(s) responsible for meeting that time frame.

6. Discuss findings with bank management, including conclusions about risks. If necessary, obtain commitment for corrective action.

7. Write a memorandum specifically setting out what the OCC should do in the future to effectively supervise country risk management practices in the bank, including time frames, staffing, and workdays required.

8. Update the OCC’s electronic information system and any applicable report of examination schedules or tables.

9. Update the examination work papers in accordance with OCC guidance.