The Office of the Comptroller of the Currency ("OCC") updated its "Deposit-Related Credit" booklet. The booklet, which is part of the Comptroller's Handbook, outlines the supervisory guidance and examination procedures used by OCC examiners to assess a bank's deposit-related credit products and services.
The updated booklet:
- provides general guidance on risks associated with check credit, overdraft protection, deposit advance products and other deposit-related credit products;
- reflects changes made by the recently issued OCC Bulletin 2018-14: "Core Lending Principles for Short-Term, Small-Dollar Installment Lending";
- offers supplemental information on the Military Lending Act;
- incorporates references to OCC Bulletin 2017-21: "Third-Party Relationships" and OCC Bulletin 2017-43: New, Modified, or Expanded Bank Products and Services--Risk Management Principles; and
- integrates the Dodd-Frank prohibition of unfair, deceptive or abusive acts or practices.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.