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Collective Investment Funds

A collective investment fund (CIF) is a bank-administered trust that holds commingled assets that meet specific criteria established by 12 CFR 9.18. The bank acts as a fiduciary for the CIF and holds legal title to the fund’s assets. CIFs allow banks to avoid costly purchases of small lot investments for their smaller fiduciary accounts.

Monthly Schedule of Short-term Investment Funds

The Monthly Schedule of Short-term Investment Funds (STIF) is used by banks that manage a STIF, pursuant to 12 CFR 9.18, to disclose information about the fund and its portfolio holdings to the OCC within five business days after each calendar month-end.  You may direct questions to David Barfield, National Bank Examiner, Market Risk Division, at (202) 649-6396 or Joel Miller, Group Leader, Asset Management, at (202) 649-6417 or John Gilmore, Bank Examiner, Market Risk Division, at (202) 649-6327.

Short-term Investment Funds Reportable Events

Consistent with the Section 9.18(b)(4)(iii)(J), banks that manage a STIF are required to notify the OCC prior to or within one business day after certain events. Reportable events include those listed below. Notification should be made to Joel Miller, Group Leader, Asset Management, at (202) 649-6417 or David Barfield, National Bank Examiner, Market Risk Division, at (202) 649-6396 or John Gilmore, Bank Examiner, Market Risk Division, at (202) 649-6327.

Reportable events include:

  1. Any difference exceeding $0.0025 between the net asset value and the mark-to-market value of a STIF participating interest as calculated using the method set forth in paragraph (b)(4)(iii)(G)(1) of this section;
  2. When a STIF has re-priced its net asset value below $0.995 per participating interest;
  3. Any withdrawal distribution-in-kind of the STIF's participating interests or segregation of portfolio participants;
  4. Any delays or suspensions in honoring STIF participating interest withdrawal requests;
  5. Any decision to formally approve the liquidation, segregation of assets or portfolios, or some other liquidation of the STIF; or
  6. In those situations when a bank, its affiliate, or any other entity provides a STIF financial support, including a cash infusion, a credit extension, a purchase of a defaulted or illiquid asset, or any other form of financial support in order to maintain a stable net asset value per participating interest;

Learn More

Collective Investment Funds (Comptroller’s Handbook, May 2014)
Provides an overview of collective investment fund risks and a framework for managing them.


BC=Banking Circular
IL=Interpretive Letter

Annual Admissions and Withdrawals under 12 CFR 9.18 (IL 920, December 2001)
Covers requests for an exemption to permit annual admissions to and withdrawals from a collective investment fund

Application of Securities Laws to Common Trust Funds (BC 247, September 1990)
Covers the requirement to register common trust funds or funds where the underlying accounts are set up for investment in the common fund or lack a bona fide fiduciary purpose

CIF Distribution Delay due to Illiquid Assets (IL 1121, August 2009)

Common Trust Funds - Method of Distribution (IL 841, November 1998)

Index & Model-driven CIF - Fees (IL 1120, August 2009)

Index & Model-drive CIF - Benchmarks (IL 1119, August 2009)

IRAs in Registered Common Trust Funds Part 1 and Part II (IL 734, July 1996)
Covers amending the trust of a registered collective investment fund to permit investment of tax-exempt employee retirement or pension plans

Nondiscretionary Custodian for Collective Investment Funds (IL 884, January 2000)
Covers investing employee benefit plan account assets held by a national bank as directed agent or nondiscretionary custodian

Pooling of Fiduciary Accounts and Self Deposit in Collective Fund (IL 969, April 2003)
Covers pooling funds of individual fiduciary accounts and self-depositing them collectively in a short-term investment fund

Related News and Issuances
Publish DateIdentifierTitle
03/18/2015  NR 2015-37, Comptroller of the Currency Issues Statement Regarding Bank Investment in the Municipal Securities Market
05/28/2014  OCC 2014-25, Collective Investment Funds: Comptroller's Handbook Booklet Revision and Rescission
10/10/2012  OCC 2012-31, Short-Term Investment Funds: Final Rule