1 OCC Supervision Issues FIRMA Risk Management Conference March 30, 2010.

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Presentation transcript:

1 OCC Supervision Issues FIRMA Risk Management Conference March 30, 2010

2 OCC Supervision Issues Strategy/Risk Considerations

3 Investment Issues Investment Objectives Third Party Investment Managers Unique Investment Products or Strategies Investment Performance Fixed Income Strategies

4 Strategy/Risk Considerations Conflicts of Interest Issues Fee Arrangements Affiliate/own bank cash sweep products Affiliated investments

5 Strategy/Risk Considerations Other Supervision Issues Internal Controls Regulation R Changes to OCC Risk Assessment System (RAS) Pending Publications/Issuances Call Report Changes

6 OCC Policy Initiatives AM Risk Issues on Horizon

7 Asset Management Risk Areas Regulatory Issues Financial Regulatory Reform proposals call for greater transparency of risks, returns, and the costs of different investment choices. Potential DOL regulation, or Congressional action, that compels substantial new fee and conflict disclosures for EB accounts.

8 Asset Management Risk Areas Collective Investment Fund Issues SEC revisions to Rule 2(a)(7) – Money Market Mutual Funds Potential revisions to 12 CFR 9.18 – Short-term Investment Funds (STIFs).

9 Asset Management Risk Areas Amended SEC RIA Custody Rules Various compliance dates for specific provisions.” More stringent requirements and controls Banks serving as qualified custodian for RIA’s will be impacted by new rules.

10 Asset Management Risk Areas Hedge Fund Issues Working with our Financial Markets Group to assess impact on both Asset Management and Commercial sides of the bank. If adopted as is, would limit bank sponsorship of hedge funds and private equity funds.

11 OCC Asset Management Handbooks  Asset Management  Collective Investment Funds  Conflicts of Interest  Custody Services  Investment Management Services  Personal Fiduciary Services  Retail Non deposit Investment Sales  Retirement Plan Services  Insurance Activities Handbooks and Bulletins are available at

12 Contact information: Joseph Sifuentes Phone (202) Joel Miller Asset Management Group Leader Phone: (202)