Provide the EIC with brief conclusions on the following:

• Quantity of risk

• Quality of risk management

• Any concerns and/or recommendations

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: Compliance, Credit, Foreign Currency Translation, Interest Rate, Liquidity, Price, Reputation, Strategic, Transaction

• Risk Conclusions: High, Moderate, or Low

• Risk Direction: Increasing, Stable, or Decreasing

Determine in consultation with the EIC, if the risks identified are significant enough to merit bringing them to the board’s attention in the report of examination. If so, prepare items for inclusion under the heading Matters Requiring Board Attention (MRBA).

• MRBA should cover practices that:

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

  • Result in substantive noncompliance with laws.

• MRBA should discuss:

  • Causative factors contributing to the problem.

  • Consequences of inaction.

  • Management’s commitment for corrective action.

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

Discuss with appropriate officer(s), and prepare report summaries that address the following:

• Concentrations.

• Violations of laws, regulations, and rulings.

• Canceled due from foreign bank—demand deposit lines that are unpaid.

• Internal control exceptions and deficiencies, or noncompliance with written policies, practices, and procedures.

• Any items to be considered for charge-off.

• Uncorrected audit deficiencies.

• Due from foreign bank—demand deposits:

  • Not supported by current and complete financial information.

  • On which documentation is deficient.

  • Which for any other reason are questionable as to quality and ultimate collection.

  • Which are criticized.

  • Other matters regarding the condition of the department.

Forward a list of due from bank accounts to examiners assigned “Investment Securities” and “Loan Portfolio Management.”

Forward the following data to the examiner assigned “Funds Management”:

• A listing, by maturity and amount, of due from banks—time deposits.

• The amounts of due from banks—demand that exceed the required reserve balance at the Federal Reserve bank and that exceed the working balances at correspondent banks.

Prepare a memorandum and update the work programs with any information that will facilitate future examinations.

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

Organize and reference working papers in accordance with OCC guidance.