The Office of the Comptroller of the Currency (OCC) recently released an updated and substantially revised section of its Comptroller’s Handbooktitled “Retail Nondeposit Investment Products” (the Booklet). The Booklet replaces the previous booklet of the same name that was issued in February 1994. It is intended to provide guidance for bank examiners on activities of national banks and federal savings associations (collectively, banks) involved in recommending and selling nondeposit investment products to retail customers.
Overall, the Booklet reflects the OCC’s increasing focus in recent years on the need for banks to implement strong risk-management processes and policies commensurate with their activities, as well as oversight of these activities by senior bank management and banks’ boards of directors. Both banks that directly engage in the sale of retail nondeposit investment products (RNDIPs) and bank-affiliated or unaffiliated broker-dealers, insurance agents, and registered investment advisers that provide services and products to certain customers on behalf of banks will need to become familiar with the supervisory expectations set out in the Booklet and incorporate, as needed, recommended business and information-sharing practices into their operations.