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Collective Investment Funds

A collective investment fund (CIF) is a bank-administered trust that holds commingled assets that meet specific criteria established by 12 CFR 9.18. The bank acts as a fiduciary for the CIF and holds legal title to the fund’s assets. CIFs allow banks to avoid costly purchases of small lot investments for their smaller fiduciary accounts.

Monthly Schedule of Short-term Investment Funds

The Monthly Schedule of Short-term Investment Funds (STIF) is used by banks that manage a STIF, pursuant to 12 CFR 9.18, to disclose information about the fund and its portfolio holdings to the OCC within five business days after each calendar month-end.  You may direct questions to Joel Miller, Group Leader, Asset Management, at (202) 649-6417 or John Gilmore, Bank Examiner, Market Risk Division, at (202) 649-6327.

Short-term Investment Funds Reportable Events

Consistent with the Section 9.18(b)(4)(iii)(J), banks that manage a STIF are required to notify the OCC prior to or within one business day after certain events. Reportable events include those listed below. Notification should be made to Joel Miller, Group Leader, Asset Management, at (202) 649-6417 or  John Gilmore, Bank Examiner, Market Risk Division, at (202) 649-6327.

Reportable events include:

  1. Any difference exceeding $0.0025 between the net asset value and the mark-to-market value of a STIF participating interest as calculated using the method set forth in paragraph (b)(4)(iii)(G)(1) of this section;
  2. When a STIF has re-priced its net asset value below $0.995 per participating interest;
  3. Any withdrawal distribution-in-kind of the STIF's participating interests or segregation of portfolio participants;
  4. Any delays or suspensions in honoring STIF participating interest withdrawal requests;
  5. Any decision to formally approve the liquidation, segregation of assets or portfolios, or some other liquidation of the STIF; or
  6. In those situations when a bank, its affiliate, or any other entity provides a STIF financial support, including a cash infusion, a credit extension, a purchase of a defaulted or illiquid asset, or any other form of financial support in order to maintain a stable net asset value per participating interest;

Learn More

Collective Investment Funds (Comptroller’s Handbook, May 2014)
Provides an overview of collective investment fund risks and a framework for managing them.


BC=Banking Circular
IL=Interpretive Letter

Banking Circular 196, “FFIEC Supervisory Policy—Securities Lending” (May 7, 1985)

OCC Bulletin 2004-2, “Banks/Thrifts Providing Financial Support to Funds Advised by the Banking Organization or its Affiliates: Interagency Guidance” (January 5, 2004)

OCC Bulletin 2008-5, “Conflicts of Interest: Risk Management Guidance—Divestiture of Certain Asset Management Businesses” (March 6, 2008)

OCC Bulletin 2010-24, “Incentive Compensation: Interagency Guidance on Sound Incentive Compensation Policies” (June 30, 2010)

OCC Bulletin 2011-11, “Risk Management Elements: Collective Investment Funds and Outsourced Arrangements” (March 29, 2011)

OCC Bulletin 2011-12, “Sound Practices for Model Risk Management: Supervisory Guidance on Model Risk Management” (April 4, 2011)

OCC Bulletin 2012-31, “Short-Term Investment Funds: Final Rule” (October 10, 2012)

OCC Bulletin 2013-8, “Short-Term Investment Funds Reporting Requirements: Monthly Disclosures” (March 5, 2013)

OCC Bulletin 2013-29, “Third-Party Relationships: Risk Management Guidance” (October 30, 2013)

OCC Bulletin 2014-25, “Collective Investment Funds: Comptroller's Handbook Booklet Revision and Rescission” (May 28, 2014)

OCC Interpretive Letter 716, “Valuation Requirements for GICs and SICs held in Collective Funds” (December 21, 1995)

OCC Interpretive Letter 722, “Investment of Collective Fund Assets in Mutual Funds and Receipt of Fees” (March 12, 1996)

OCC Interpretive Letter 829, “Different Fund Management Fees to Collective Fund Participants” (April 9, 1998)

OCC Interpretive Letter 865, “Pooling of Securities Lending Collateral Held Pursuant to Securities Lending Agreements Qualifies for Common Trust Fund Treatment” (May 26, 1999)

OCC Interpretive Letter 884, “Investing Employee Benefit Plan Accounts Held by a National Bank as Directed Agent or Nondiscretionary Custodian in a Collective Fund” (January 13, 2000)

OCC Interpretive Letter 919, “Allocation of Costs by Model-Driven Funds to Participants Admitted to or Withdrawing From Collective Funds” (November 9, 2001)

OCC Interpretive Letter 920, “Frequency of Collective Fund Admissions and Withdrawals”  (December 6, 2001)

OCC Interpretive Letter 936, “Limitations on Collective Fund Withdrawals” (May 22, 2002)

OCC Interpretive Letter 969, “Collective Fund Limited to Funds Awaiting Investment or Distribution” (April 28, 2003)

OCC Interpretive Letter 1120, “Model-Driven Fund Fees and Conflicts” (February 20, 2009)

OCC Interpretive Letter 1121, “Real Estate Fund Withdrawal Requirements” (June 19, 2009)

Related News and Issuances
Publish DateIdentifierTitle
03/18/2015  NR 2015-37, Comptroller of the Currency Issues Statement Regarding Bank Investment in the Municipal Securities Market
05/28/2014  OCC 2014-25, Collective Investment Funds: Comptroller's Handbook Booklet Revision and Rescission
10/10/2012  OCC 2012-31, Short-Term Investment Funds: Final Rule