Risk management of investments in structured credit products should include adequate due diligence, reasonable exposure limits, accurate risk measurement, an understanding of the tranched structure, knowledge of the collateral performance, and a determination of investment suitability.
Institutions should consider credit ratings as a factor in the risk management process; however, credit ratings should not be the sole factor considered when evaluating the risk present in structured credit products.
Institutions should have a reasonable, documented, and consistently applied approach to pricing high risk, illiquid, complex structured credit products.
Examiners' classification of structured credit products is governed by the guidance in the "Uniform Agreement on the Classification of Assets and Appraisal of Securities." This guidance permits examiners to adversely classify a security when supported by current credit information despite an investment grade credit rating.
FDIC-Supervised Banks (Commercial and Savings)
Chief Executive Officer
Chief Financial Officer
Chief Investment Officer
Chief Risk Officer
Supervisory Policy Statement on Investment Securities and End-User Derivatives Activities, FIL-45-98
Uniform Agreement on the Classification of Assets and Appraisal of Securities, FIL-70-2004
Risk-Based Capital Rules
12 CFR Part 325
Risk Management of Investments in Structured Credit Products
Risk Management of Investments in Structured Credit Products - PDF (PDF Help)
Suzanne Clair, Senior Capital Markets Specialist, Capital Markets Branch, at SClair@FDIC.gov or (202) 898 6605
Ryan Sheller, Capital Markets Specialist, Capital Markets Branch, at RSheller@FDIC.gov or (202) 898 6614
FIL-20-2009 - PDF (PDF Help)
FDIC financial institution letters (FILs) may be accessed from the FDIC's Web site at www.fdic.gov/news/news/financial/2009/index.html
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Paper copies of FDIC financial institution letters may be obtained through the FDIC's Public Information Center, 3501 Fairfax Drive, E-1002, Arlington, VA 22226 (1-877-275-3342 or 703-562-2200).