Review the following to identify if previous problems require follow-up. Determine if planned corrective action was affected, and if not, why not.

• Supervisory strategy in the OCC’s Electronic Information System.

• EIC’s scope memorandum.

• Previous examination reports and working papers.

• Overall summary comments.

• Correspondence memorandum.

From the EIC, obtain the results of his or her analysis of the UBPR, BERT, and other OCC reports. Identify any concerns, trends, or changes involving due from banks.

Determine if any material changes have occurred since the last examination that would influence the level and direction of due from banks risk.

Determine, during early discussions with management:

• How management supervises due from bank accounts.

• If there have been any significant changes in policies, practices, internal controls, or personnel responsible for supervising due from banks.

• Any internal or external factors that could affect balance limitations, collateral requirements, and reporting requirements.

From the examiner assigned Internal/External Audit, obtain a copy of any significant deficiencies with due from banks. Determine if appropriate corrections have been made.

Obtain and review the most recent month end reports management uses to supervise due from banks. Some examples include:

• Listing of all due from bank accounts (domestic and foreign), including any matured and unpaid due from bank—time deposits.

• Listing of all due from bank—time accounts.

• The most recent Federal Reserve requirement calculation and working papers.

• Reconcilements for all due from bank accounts.

• Board reports, etc.

Obtain from management or the examiner assigned “International Loan Portfolio Management,” all applicable schedules relating to the due from foreign banks—demand (nostro accounts) and time, if applicable. Examples include:

• Specific guidelines in bank policies relating to due from foreign banks.

• Current listing of due from foreign banks—demand and time approved customer lines.

• Due from foreign banks—time, considered problem assets by management or criticized during the previous examination.

• The current interest rate structure.

• Delinquencies.

• Miscellaneous loan debt and credit suspense accounts.

• Criticized shared national credits.

• Interagency Country Exposure Review Committee credits.

• Any useful information resulting from the review of the minutes of the loan and discount committee or any similar committee.

• •A listing of any rebooked charged off due from foreign bank—time deposits.

• Information on directors, officers and their interests, as contained in statements required under 12 CFR 215.

Based on the performance of these steps, combined with discussions with the bank EIC and other appropriate supervisors, determine the scope of this examination and set objectives. Note: Select from among the following examination procedures those steps that are necessary to meet your objectives. All steps are seldom required in all examinations.