On February 10, the Office of the Comptroller of the Currency (OCC) issued the “Personal Fiduciary Activities” booklet of the Comptroller’s Handbook. This revised booklet replaces a similarly titled booklet issued in August 2002. This booklet provides updated guidance for examiners on risks and expected controls over personal fiduciary activities that may arise as part of the broader fiduciary and asset management activities of national banks or federal savings associations (collectively, banks). The booklet also explains the risks inherent in offering personal fiduciary products and services and provides a framework for managing those risks. Specifically, the “Personal Fiduciary Activities” booklet:
- updates references to laws and regulations to include those applicable to federal savings associations;
- clarifies and expands guidance applicable to current business practices, particularly when banks act as directed trustees under state trust laws;
- updates risk management guidance;
- updates references; and
- provides a sample personal fiduciary activities examination request letter.
The booklet is available here.