[Federal Register: February 10, 1999 (Volume 64, Number 27)]
[Notices]
[Page 6655-6659]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr10fe99-89]
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FEDERAL FINANCIAL INSTITUTIONS EXAMINATION COUNCIL
Uniform Retail Credit Classification and Account Management
Policy
AGENCY: Federal Financial Institutions Examination Council.
ACTION: Final notice.
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SUMMARY: The Federal Financial Institutions Examination Council
(FFIEC), on behalf of the Board of Governors of the Federal Reserve
System (FRB), the Federal Deposit Insurance Corporation (FDIC), the
Office of the Comptroller of the Currency (OCC), and the Office of
Thrift Supervision (OTS), collectively referred to as the Agencies, is
publishing its revisions to the Uniform Policy for Classification of
Consumer Installment Credit Based on Delinquency Status (Uniform Retail
Credit Classification Policy). The National Credit Union Administration
(NCUA), also a member of FFIEC, does not plan to adopt the policy at
this time.
The Uniform Retail Credit Classification and Account Management
Policy is a supervisory policy used by the Agencies for uniform
classification and treatment of retail credit loans in financial
institutions.
DATES: Changes in this policy that involve manual adjustments to the
institutions' policies and procedures should be implemented for
reporting in the June 30, 1999 Call Report or Thrift Financial Report,
as appropriate. Any policy changes involving programming resources,
should be implemented for reporting in the December 31, 2000 Call
Report or Thrift Financial Report, as appropriate.
FOR FURTHER INFORMATION CONTACT: FRB: William Coen, Supervisory
Financial Analyst, (202) 452-5219, Division of Banking Supervision and
Regulation, Board of Governors of the Federal Reserve System. For the
hearing impaired only, Telecommunication Device for the Deaf (TDD),
Dorothea Thompson, (202) 452-3544, Board of Governors of the Federal
Reserve System, 20th and C Streets NW, Washington, DC 20551.
FDIC: James Leitner, Examination Specialist, (202) 898-6790,
Division of Supervision. For legal issues, Michael Phillips, Counsel,
(202) 898-3581, Supervision and Legislation Branch, Federal Deposit
Insurance Corporation, 550 17th Street NW, Washington, DC 20429.
OCC: Stephen Jackson, National Bank Examiner, Credit Risk Division,
(202) 874-4473, or Ron Shimabukuro, Senior Attorney, Legislative and
Regulatory Activities Division (202) 874-5090, Office of the
Comptroller of the Currency, 250 E Street SW, Washington, DC 20219.
OTS: William J. Magrini, Senior Project Manager, (202) 906-5744,
Supervision Policy; or Vern McKinley, Senior Attorney, (202) 906-6241,
Regulations and Legislation Division, Chief Counsel's Office, Office of
Thrift Supervision, 1700 G Street NW, Washington, DC 20552.
SUPPLEMENTARY INFORMATION:
Background Information
On June 30, 1980, the FRB, FDIC, and OCC adopted the FFIEC uniform
policy for classification of open-end and closed-end credit (1980
policy). The Federal Home Loan Bank Board, the predecessor of the OTS,
adopted the 1980 policy in 1987. The 1980 policy established uniform
guidelines for classification of installment credit based on
delinquency status and provided different charge-off time frames for
open-end and closed-end credit. The 1980 policy recognized the
statistical validity of determining losses based on past due status.
The Agencies undertook a review of the 1980 policy as part of their
review of all written policies mandated by Section 303(a) of the Riegle
Community Development and Regulatory Improvement Act of 1994 (CDRI). As
noted in their September 23, 1996 Joint Report to Congress on CDRI
review efforts,1 the Agencies believe that the 1980 policy
should be revised due to changes that have taken place within the
industry.
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\1\ Joint Report: Streamlining of Regulatory Requirements--
Section 303(a)(3) of the Riegle Community Development and Regulatory
Improvement Act of 1994, page I-41.
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In 1980, open-end credit consisted largely of credit card accounts
with small lines of credit to the most creditworthy borrowers. Today,
open-end credit generally includes accounts with much larger lines of
credit to diverse borrowers with a variety of risk profiles. The change
in those accounts and inconsistencies in reporting and charge-off
practices of open-end accounts by financial institutions prompted the
Agencies to consider several revisions to the 1980 policy.
Specifically, the FFIEC had concerns
[[Page 6656]]
that a number of institutions were not following existing policy
guidance for charging off open-end accounts based on past due status.
Charge-off practices ranged from 120 days to 240 days. This range
reflected, in part, differing interpretations by some institutions with
regard to the policy's guidance to charge off open-end loans by the
seventh zero billing cycle. In addition, the 1980 policy did not
establish guidance for charging off fraudulent accounts, accounts of
deceased persons, or accounts of borrowers in bankruptcy (accounts in
bankruptcy), which currently account for a large portion of total
charge-offs. Moreover, no classification guidance existed for
residential and home equity loans--a significant amount of consumer
credit. Finally, no uniform guidance existed for handling re-aging of
open-end credit, or extensions, deferrals, renewals, or re-writes of
closed-end credit.
As a result of these concerns, the FFIEC published two notices in
the Federal Register on September 12, 1997 (1997 Notice) (62 FR 48089)
and on July 6, 1998 (1998 Notice) (63 FR 36403) requesting comment on
various proposed revisions to the 1980 policy. Comments received during
both periods provided extremely useful guidance to the FFIEC. After
careful consideration, the FFIEC has made several changes to its
earlier proposals and adopted those changes in this final policy
statement. While the comments proved extremely helpful, the FFIEC is
mindful of the Agencies' missions to promote safety and soundness of
the financial industry and to recommend regulatory policies and
standards that further those missions. In keeping with the Agencies'
goals of promoting safety and soundness, certain aspects of the final
notice are a departure from what the majority of commenters suggested.
Comments Received
The FFIEC received a total of 128 comments in response to the 1998
Notice. They came from 25 banks and thrifts, 19 bank holding companies,
8 regulatory agencies, 13 trade groups, 33 consumer credit counseling
services, and 30 other companies and individuals. The following is a
summary.
1a. Charge-off Policy for Open-End and Closed-End Credit. The 1998
Notice proposed two options for charging off delinquent accounts. The
first proposed that both closed-end and open-end credit be charged off
at 150 days delinquency. The second option proposed to retain, but
clarify existing policy; charge off closed-end credit at 120 days
delinquency and charge off open-end credit at 180 days delinquency.
Commenters were overwhelmingly in favor of retaining the existing 120/
180 charge-off time frames. Commenters representing the credit card
industry stated that shortening time frames to 150 days would cause a
$2 billion dollar write-off initially, with further impact during
implementation. Moreover, credit card companies and community groups
and counseling services stated that they needed those extra 30 days in
the period from 150 days delinquency to 180 days delinquency to work
with troubled borrowers. Several lenders indicated that they can
collect ten percent or more of accounts during that time period. After
careful consideration, the FFIEC has decided not to pursue uniform
charge-off time frames for open-end and closed-end credit at this time.
Moreover, since the revision to the 1980 policy was initiated, the
majority of institutions whose open-end charge-off policy exceeded 180
days have brought themselves into compliance. However, because of
confusion over the terminology of ``seven zero billing cycles,'' the
FFIEC decided to eliminate that language in the final policy.
Additionally, the FFIEC is adopting re-aging guidance so that greater
consistency and clarity in reporting among retail credit lenders will
be achieved.
1b. Substandard classification policy.--The majority of the
comments received in response to the 1997 Notice supported retention of
classifying open-end and closed-end consumer credit at 90 days
delinquency. No objections were received in response to the 1998
Notice. The FFIEC agrees with the commenters. It believes that when an
account is 90 days past due, it displays weakness warranting
classification. Therefore, open-end and closed-end accounts will
continue to be classified Substandard at 90 days past due.
2. Bankruptcy, fraud and deceased accounts. Bankruptcy.--The 1998
Notice requested comment on two proposals relating to treatment of
accounts in bankruptcy. First, the 1998 Notice asked whether unsecured
loans in bankruptcy should be charged off by the end of the month in
which a creditor is notified of the bankruptcy filing. Second, the 1998
Notice proposed that for secured and partially secured accounts in
bankruptcy, the collateral should be evaluated and any deficiency
balance charged off within 30 days of notification.
The majority of the commenters believed that revised bankruptcy
legislation would pass in the second session of the 105th Congress and
asked the FFIEC to defer a decision on this issue pending new
legislation. The FFIEC was prepared to conform the final policy
statement to any new legislation; however, no legislation was enacted.
Because widespread inconsistencies in charge-off practices on accounts
in bankruptcy continue to exist, the FFIEC is adopting guidance at this
time. If and when bankruptcy legislation is enacted, the FFIEC will
review the policy statement to determine if any revisions are needed.
Commenters objected to both of the proposed time frames on bankrupt
accounts. Fifty commenters opposed the proposal for unsecured accounts
in bankruptcy versus only ten who supported it. Twenty-two commenters
opposed the proposed handling of secured and unsecured accounts in
bankruptcy, while only 11 supported it. A number of creditors noted
that an accurate determination of loss on accounts in bankruptcy
realistically cannot be made until after the meeting with creditors.
This may be anywhere from 10 to 45 days or more after the bankruptcy
filing, depending upon the case load of the bankruptcy court. The FFIEC
shares the concerns of these commenters. Consequently, the final policy
statement has been revised, for unsecured, partially secured, and fully
secured accounts in bankruptcy, to allow creditors up to 60 days from
their receipt of the bankruptcy notice filing to charge off those
amounts deemed unrecoverable. However, accounts should be charged off
no later than the respective 120-day or 180-day time frames for closed-
end and open-end credit.
Fraud.--The 1998 Notice proposed that accounts affected by fraud be
charged off within 90 days of discovery of the fraud or within the
general charge-off time frames established by this final policy
statement, whichever is shorter. The majority of the commenters
supported this proposal. While the FFIEC recognizes that a fraud
investigation may last more than 30 days, it believes that 90 days
provides an institution sufficient time to charge off an account
affected by fraud. Therefore, this final policy statement adopts this
provision as proposed.
Accounts of deceased persons.--The 1998 Notice proposed that
accounts of deceased persons should be charged off when loss is
determined or within the classification time frames adopted by this
final policy statement. A majority of the commenters supported this
proposal. As discussed in the 1998 Notice, the FFIEC agrees that
determination of repayment potential on an account of a deceased person
may
[[Page 6657]]
take months when working through a trustee or the family. However, the
FFIEC believes the time frames established by this final policy
statement provide adequate time to determine the amount of the loss and
charge off that amount. For this reason, the final policy statement
adopts this provision as proposed.
3. Partial payments.--The 1998 Notice proposed that in addition to
the existing guidance that 90 percent of a contractual payment may be
considered a full payment in computing delinquency, the FFIEC allows an
institution to aggregate payments to give a borrower credit for partial
payments. The proposal stated that only one method should be allowed
throughout a loan portfolio. Some institutions stated that they were
already using both methods. One recommendation made by the commenters
and supported by the FFIEC was to eliminate the guidance that one
method be used consistently throughout the portfolio. These commenters
noted that these methods are used for different reasons. For instance,
the 90 percent method may handle errors in check writing while the
aggregate method enables institutions to work flexibly with troubled
borrowers. The FFIEC agrees with these commenters. Therefore, this
final policy statement has been revised to allow an institution to use
both methods in dealing with partial payments.
4. Re-aging, extension, renewal, deferral, or rewrite policy.--The
1998 Notice proposed a number of criteria be established before a re-
aging, extension, renewal, deferral, or rewrite of an account. A
majority of commenters supported the criteria that the borrower should
show a renewed willingness and ability to pay and that the account
should meet agency and bank guidelines. However, many commenters
generally opposed the following criteria:
<bullet> The borrower should make three minimum consecutive
payments or lump sum equivalent before being re-aged.
<bullet> An account should not be re-aged, extended, renewed,
deferred, or rewritten more than once within any twelve-month period.
<bullet> An account should be in existence for at least twelve
months before it can be re-aged, extended, deferred, or rewritten.
<bullet> No more than two re-agings, extensions, renewals,
deferrals, or rewrites should occur during the lifetime of the account.
<bullet> The re-aged balance should not exceed the predelinquency
credit limit.
While the FFIEC appreciates concerns of these commenters that
flexibility is required to work with troubled borrowers, it also
recognizes this has the greatest potential for masking the delinquency
status of accounts. Consistent guidelines are needed to ensure the
integrity of financial records and prevent abuses (such as automated
re-aging programs). In addition, the FFIEC believes that an account
should show some performance before a re-aging is allowed. In response
to commenters' concerns, the Agencies modified the proposed guidelines.
For example, to provide flexibility for lenders to work with borrowers,
but still maintain the integrity of asset quality reports, the Agencies
changed the proposed re-aging guidelines to allow accounts to be re-
aged not more than twice in a five-year period. Therefore, in
considering the commenters' views and the Agencies' missions of
ensuring safety and soundness of institutions' loan assets, the
following criteria are being adopted:
<bullet> The borrower should show a renewed willingness and ability
to repay.
<bullet> The account should meet agency and bank policy standards.
<bullet> The borrower should make three minimum consecutive monthly
payments or the lump sum equivalent before an account is re-aged.
<bullet> The account should be in existence at least nine months.
<bullet> An account should not be re-aged, deferred, extended,
renewed or rewritten more than once within any twelve-month period, and
not more than twice in a five-year period.
<bullet> An over limit account may be re-aged at its outstanding
balance (including the over limit balance, interest, and fees) but new
credit should not be extended until the account balance is below its
designated credit limit.
5. Residential and home equity loans.--The 1998 Notice proposed
that institutions holding both one- to four-family and home equity
loans to the same borrower that are delinquent 90 days or more with
loan-to-value ratios greater than 60 percent be classified Substandard.
In addition, the FFIEC proposed that a current evaluation of collateral
be made by the time the loan is 120 or 180 days past due for a closed-
end or open-end account, respectively.
Commenters were almost equally divided on this proposal during the
1998 Notice. However, in response to the 1997 Notice, the majority of
the commenters supported classifying the loans Substandard when they
are 90 days delinquent. Some commenters supported a different loan-to-
value ratio. Exposure to loss increases as the loan-to-value ratio of a
real estate loan increases. The agencies believe, however, that for
one- to four-family residential loans with loan-to-value ratios of 60
percent or less, ample collateral support exists to satisfy the loan.
Therefore the FFIEC believes that the classification of such loans is
not necessary. This final policy statement adopts the provision as
proposed.
In response to the 1998 Notice, the commenters opposed the
collateral evaluation. In response to the 1997 Notice, the majority of
the commenters supported the proposal that a collateral evaluation be
obtained. However, from the comments it appears that the proposal was
not clear because many commenters believed that a ``full'' appraisal
was required. The FFIEC agrees that the policy indicating that a
collateral evaluation be obtained was not intended to be burdensome and
that a full appraisal is not required. The policy reaffirms the need to
determine the amount of loss in the loan when delinquency reaches the
time frames for charge-off for non-real estate loans.
Implementation Period
In the 1998 Notice, it said that if the Agencies retained the 120/
180-day charge off time frames, the implementation period would begin
January 1, 1999. However, the Agencies recognize that for some
institutions, this may involve programming changes. The Agencies expect
institutions to begin implementation of this policy upon publication.
Manual changes should be implemented for reporting in the June 30, 1999
Call Report or Thrift Financial Report, as appropriate. Changes
involving programming resources should be implemented for reporting in
the December 31, 2000 Reports.
Final Policy Statement
After careful consideration of all the comments, the FFIEC adopts
this final policy statement. In general, this final policy statement:
<bullet> Establishes a uniform charge-off policy for open-end
credit at 180 days delinquency and closed-end credit at 120 days
delinquency.
<bullet> Provides uniform guidance for loans affected by
bankruptcy, fraud, and death.
<bullet> Establishes guidelines for re-aging, extending, deferring,
or rewriting past due accounts.
<bullet> Classifies certain delinquent residential mortgage and
home equity loans.
<bullet> Broadens recognition of partial payments that qualify as
full payments.
The FFIEC considered the effect of generally accepted accounting
[[Page 6658]]
principles (GAAP) on this statement. GAAP requires prompt recognition
of loss for assets or portions of assets deemed uncollectible. The
FFIEC believes that because this final policy statement provides for
prompt recognition of losses, it is fully consistent with GAAP.
The final statement is:
Uniform Retail Credit Classification and Account Management Policy
2
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\2\ Retail Credit includes open-end and closed-end credit
extended to individuals for household, family, and other personal
expenditures. It includes consumer loans and credit cards. For the
purpose of this policy, retail credit also includes loans to
individuals secured by their personal residence, including home
equity and home improvement loans.
The regulatory classifications used for retail credit are
Substandard, Doubtful, and Loss. These are defined as follows:
Substandard: An asset classified Substandard is protected
inadequately by the current net worth and paying capacity of the
obligor, or by the collateral pledged, if any. Assets so classified
must have a well-defined weakness or weaknesses that jeopardize the
liquidation of the debt. They are characterized by the distinct
possibility that the institution will sustain some loss if the
deficiencies are not corrected. Doubtful: An asset classified
Doubtful has all the weaknesses inherent in one classified
Substandard with the added characteristic that the weaknesses make
collection or liquidation in full, on the basis of currently
existing facts, conditions, and values, highly questionable and
improbable. Loss: An asset, or portion thereof, classified Loss is
considered uncollectible, and of such little value that its
continuance on the books is not warranted. This classification does
not mean that the asset has absolutely no recovery or salvage value;
rather, it is not practical or desirable to defer writing off an
essentially worthless asset (or portion thereof), even though
partial recovery may occur in the future.
Although the Board of Governors of the Federal Reserve System,
Federal Deposit Insurance Corporation, Office of the Comptroller of
the Currency, and Office of Thrift Supervision do not require
institutions to adopt identical classification definitions,
institutions should classify their assets using a system that can be
easily reconciled with the regulatory classification system.
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Evidence of the quality of consumer credit soundness is indicated
best by the repayment performance demonstrated by the borrower. Because
retail credit generally is comprised of a large number of relatively
small balance loans, evaluating the quality of the retail credit
portfolio on a loan-by-loan basis is inefficient and burdensome for the
institution being examined and examiners. Therefore, in general, retail
credit should be classified based on the following criteria:
<bullet> Open-end and closed-end retail loans past due 90
cumulative days from the contractual due date should be classified
Substandard.
<bullet> Closed-end retail loans that become past due 120
cumulative days and open-end retail loans that become past due 180
cumulative days from the contractual due date should be charged off.
The charge-off should be taken by the end of the month in which the
120-or 180-day time period elapses.3
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\3\ Fixed payment open-end retail accounts that are placed on a
closed-end repayment schedule should follow the closed-end charge-
off time frames.
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<bullet> Unless the institution can clearly demonstrate and
document that repayment on accounts in bankruptcy is likely to occur,
accounts in bankruptcy should be charged off within 60 days of receipt
of notification of filing from the bankruptcy court or within the time
frames specified in this classification policy, whichever is shorter.
The charge off should be taken by the end of the month in which the
applicable time period elapses. Any loan balance not charged off should
be classified Substandard until the borrower re-establishes the ability
and willingness to repay (with demonstrated payment performance for six
months at a minimum) or there is a receipt of proceeds from liquidation
of collateral.
<bullet> Fraudulent loans should be charged off within 90 days of
discovery or within the time frames specified in this classification
policy, whichever is shorter. The charge-off should be taken by the end
of the month in which the applicable time period elapses.
<bullet> Loans of deceased persons should be charged off when the
loss is determined or within the time frames adopted in this
classification policy, whichever is shorter. The charge-off should be
taken by the end of the month in which the applicable time period
elapses.
<bullet> One- to four-family residential real estate loans and home
equity loans that are delinquent 90 days or more with loan-to-value
ratios greater than 60 percent, should be classified Substandard.
<bullet> When a residential or home equity loan is 120 days past
due for closed-end credit and 180 days past due for open-end credit, a
current assessment of value 4 should be made and any
outstanding loan balance in excess of the fair value of the property,
less cost to sell, should be classified Loss.
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\4\ Additional information about content requirements of
evaluations can be found in the ``Interagency Appraisal and
Evaluation Guidelines'', October 27, 1994. For example, under
certain circumstances, evaluations could be derived from an
automated collateral evaluation model, drive-by inspection by bank
employee or contracted employee, and real estate market comparable
sales similar to the institution's collateral.
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Properly secured residential real estate loans with loan-to-value
ratios equal to or less than 60 percent are generally not classified
based solely on delinquency status. Home equity loans to the same
borrower at the same institution as the senior mortgage loan with a
combined loan-to-value ratio equal to or less than 60 percent, should
not be classified. However, home equity loans where the institution
does not hold the senior mortgage, that are delinquent 90 days or more
should be classified Substandard, even if the loan-to-value ratio is
equal to, or less than, 60 percent.
Other Considerations for Classification
If an institution can clearly document that the delinquent loan is
well secured and in the process of collection, such that collection
will occur regardless of delinquency status, then the loan need not be
classified. A well secured loan is collateralized by a perfected
security interest in, or pledges of, real or personal property,
including securities, with an estimated fair value, less cost to sell,
sufficient to recover the recorded investment in the loan, as well as a
reasonable return on that amount. In the process of collection means
that either a collection effort or legal action is proceeding and is
reasonably expected to result in recovery of the loan balance or its
restoration to a current status, generally within the next 90 days.
This policy does not preclude an institution from adopting an
internal classification policy more conservative than the one detailed
above. It also does not preclude a regulatory agency from using the
Doubtful or Loss classification in certain situations if a rating more
severe than Substandard is justified. Loss in retail credit should be
recognized when the institution becomes aware of the loss, but in no
case should the charge off exceed the time frames stated in this
policy.
Partial Payments on Open-End and Closed-End Credit
Institutions should use one of two methods to recognize partial
payments. A payment equivalent to 90 percent or more of the contractual
payment may be considered a full payment in computing delinquency.
Alternatively, the institution may aggregate payments and give credit
for any partial payment received. For example, if a regular installment
payment is $300 and the borrower makes payments of only $150 per month
for a six-month period, the loan would be $900 ($150 shortage times six
payments), or three full months delinquent. An institution may use
either or both methods in its portfolio, but may not use both methods
simultaneously with a single loan.
[[Page 6659]]
Re-aging, Extensions, Deferrals, Renewals, or Rewrites 5
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\5\ Certain advertising and marketing programs, like ``skip-a-
payment'' and holiday payment deferral programs are not subject to
this portion of the policy.
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Re-aging is the practice of bringing a delinquent account current
after the borrower has demonstrated a renewed willingness and ability
to repay the loan by making some, but not all, past due payments. Re-
aging of open-end accounts, or extensions, deferrals, renewals, or
rewrites of closed-end accounts should only be used to help borrowers
overcome temporary financial difficulties, such as loss of job, medical
emergency, or change in family circumstances like loss of a family
member. A permissive policy on re-agings, extensions, deferrals,
renewals, or rewrites can cloud the true performance and delinquency
status of the portfolio. However, prudent use of a policy is acceptable
when it is based on recent, satisfactory performance and the true
improvement in a borrower's other credit factors, and when it is
structured in accordance with the institution's internal policies.
The decision to re-age a loan, like any other modification of
contractual terms, should be supported in the institution's management
information systems. Adequate management information systems usually
identify and document any loan that is extended, deferred, renewed, or
rewritten, including the number of times such action has been taken.
Documentation normally shows that institution personnel communicated
with the borrower, the borrower agreed to pay the loan in full, and the
borrower shows the ability to repay the loan.
Institutions that re-age open-end accounts should establish a
reasonable written policy and adhere to it. An account eligible for re-
aging, extension, deferral, renewal, or rewrite should exhibit the
following:
<bullet> The borrower should show a renewed willingness and ability
to repay the loan.
<bullet> The account should exist for at least nine months before
allowing a re-aging, extension, renewal, referral, or rewrite.
<bullet> The borrower should make at least three minimum
consecutive monthly payments or the equivalent lump sum payment before
an account is re-aged. Funds may not be advanced by the institution for
this purpose.
<bullet> No loan should be re-aged, extended, deferred, renewed, or
rewritten more than once within any twelve month period; that is, at
least twelve months must have elapsed since a prior re-aging. In
addition, no loan should be re-aged, extended, deferred, renewed, or
rewritten more than two times within any five-year period.
<bullet> For open-end credit, an over limit account may be re-aged
at its outstanding balance (including the over limit balance, interest,
and fees). No new credit may be extended to the borrower until the
balance falls below the designated predelinquency credit limit.
Examination Considerations
Examiners should ensure that institutions adhere to this policy.
Nevertheless, there may be instances that warrant exceptions to the
general classification policy. Loans need not be classified if the
institution can document clearly that repayment will occur irrespective
of delinquency status. Examples might include loans well secured by
marketable collateral and in the process of collection, loans for which
claims are filed against solvent estates, and loans supported by valid
insurance claims.
The uniform classification and account management policy does not
preclude examiners from reviewing and classifying individual large
dollar retail credit loans that exhibit signs of credit weakness
regardless of delinquency status.
In addition to reviewing loan classifications, the examiner should
ensure that the institution's allowance for loan and lease loss
provides adequate coverage for inherent losses. Sound risk and account
management systems, including a prudent retail credit lending policy,
measures to ensure and monitor adherence to stated policy, and detailed
operating procedures, should also be implemented. Internal controls
should be in place to ensure that the policy is followed. Institutions
lacking sound policies or failing to implement or effectively follow
established policies will be subject to criticism.
Implementation
Changes in this policy that involve manual adjustments to an
institution's policies and procedures should be implemented for
reporting in the June 30, 1999 Call Report or Thrift Financial Report,
as appropriate. Any policy changes requiring programming resources
should be implemented for reporting in the December 31, 2000 Call
Report or Thrift Financial Report, as appropriate.
Dated: February 4, 1999.
Keith J. Todd,
Executive Secretary, Federal Financial Institutions Examination
Council.
[FR Doc. 99-3181 Filed 2-9-99; 8:45 am]
BILLING CODES FRB: 6210-01-P (25%); FDIC: 6714-01-P (25%); OTS: 6720-
01-P (25%); OCC: 4810-33-P (25%)
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