The minimum procedures are designed to enable examiners to assess the bank’s exposure to retail credit risk and to identify significant changes in the bank’s performance, products, or markets during supervisory activities. The procedures provide the steps necessary for a comprehensive retail lending examination in small or less complex operations. They also serve as the base retail lending procedures for larger more complex operations.
Depending on the size, complexity, and risk profile of the retail portfolio, the minimum procedures may provide sufficient information to reach conclusions. They may also indicate the need for a more extensive review of all or parts of a bank’s retail lending activities (e.g., significant changes, growth, deteriorating performance, higher-risk products, or complex operations). If more in-depth procedures are warranted, examiners should employ some or all of the supplemental procedures.
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