Prepare a summary memorandum to the LPM examiner or EIC regarding the leveraged lending portfolio. Draft conclusions on

• Asset quality of the portfolio.

• The adequacy of policies and underwriting standards.

• Volume and severity of underwriting and policy exceptions.

• Underwriting quality of sample loans.

• Quality of portfolio supervision.

• Concentrations of credit.

• Adequacy and timeliness of MIS.

• Adequacy of loan control functions.

• Compliance with applicable laws, rules, and regulations.

• Quality of staffing.

• Reliability of internal risk ratings.

• Appropriateness of strategic and business plans

• The extent to which leveraged lending credit risk and credit risk management practices affect aggregate loan portfolio risk.

• Recommended corrective action regarding deficient policies, procedures, and practices. (Include whether management commits to the corrective action.)

• Any other concerns.

Provide input to help the EIC assign the bank CAMELS component ratings for asset quality and management.

Recommend risk assessments for the leveraged lending portfolio. Refer to the “Large Bank Supervision” and “Community Bank Supervision” booklets in the Comptroller’s Handbook for guidance.

Based on discussions with the EIC and bank management, and information in the summary memorandum, prepare a brief comment on leveraged lending for inclusion in the ROE.

Discuss examination findings and conclusions with the examiner assigned loan portfolio management and the EIC. If necessary, compose “Matters Requiring Attention” (MRA) for the loan portfolio management examination. MRAs 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.

• MRAs should discuss

• Causes of the problem.

• Consequences of inaction.

• Management’s commitment to corrective action.

• The time frame and persons responsible for corrective action.

Discuss findings with bank management, including conclusions about risks and risk management. Obtain commitments for corrective action.

Write a memorandum or update the supervisory strategy, or both, specifically setting out what the OCC should do in the future to effectively supervise the leveraged lending function at the bank. Include time frames, staffing, and workdays required.

Update the supervisory record and any applicable report of examination schedules or tables.

Update the examination work papers in accordance with OCC guidance.