Provide EIC with brief conclusion regarding:

• The adequacy of written policies relating to floor plan loans.

• The manner in which bank officers are conforming with established policy.

• Schedules that were discovered to be incorrect or incomplete.

• The quality of departmental management.

• Internal control deficiencies or exceptions.

• Other matters of significance.

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 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 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 findings with management including conclusions regarding applicable risks.

• Delinquent loans, including breakout of “bad” debts as defined in 12 USC 56.

• Extensions of credit to employees, officers, directors, and/or their interests.

• Loans on which collateral documentation is deficient.

• Recommended corrective action when policies, practices, or procedures are deficient.

• Other matters regarding the condition of the department.

As appropriate, prepare a brief floor plan lending comment for inclusion in the report of examination.

• Quantity of risk.

• Quality of risk management.

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

• Transfer liability and other pertinent information to examiner assigned to “Installment Loans.” Credit review will be performed in conjunction with the analysis of dealer indirect lines.

• 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.