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News and Issuances

OCC 2010-3
To: Chief Executive Officers and Compliance Officers of All National Banks, Department and Division Heads, and All Examining Personnel

Description: Proposed Guidance

The Office of the Comptroller of the Currency, along with the other members of the Federal Financial Institutions Examination Council (FFIEC), recently released proposed guidance on reverse mortgage products. The guidance is designed to help financial institutions ensure that their risk management and consumer protection practices adequately address the compliance and reputation risks raised by reverse mortgage lending.

The proposed guidance addresses the general features of reverse mortgage products, relevant legal requirements, and consumer protection concerns. It focuses on the need for banks, thrifts, and credit unions to provide clear and balanced information to consumers about the risks and benefits of these products. Such information should be provided while consumers are making decisions about these products and should address the specific matters listed in the guidance, including informing consumers of available alternatives to reverse mortgages. The proposed guidance also states that institutions should require that consumers receive qualified independent counseling and take steps to avoid any appearance of a conflict of interest. The proposed guidance addresses related policies, procedures, internal controls, and third-party risk management.

The FFIEC members request comments on the proposed guidance by February 16, 2010. The proposed guidance is attached.

If you have questions, please contact your supervisory office or the Compliance Policy Division at (202) 874-4428.

Ann F. Jaedicke
Deputy Comptroller for Compliance Policy

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