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OCC Bulletin 2015-3 | January 14, 2015

Conflicts of Interest: Revised Comptroller's Handbook Booklet and Rescissions


Chief Executive Officers and Asset Management Personnel of All National Banks and Federal Savings Associations, Department and Division Heads, All Examining Personnel, and Other Interested Parties


The Office of the Comptroller of the Currency (OCC) issued today the “Conflicts of Interest” booklet of the Comptroller’s Handbook. This booklet replaces a booklet of the same title issued in June 2000.

This booklet, which has been revised to include the supervision of federal savings associations (FSA), provides updated guidance for examiners on risks and expected controls over conflicts of interest that may arise in asset management activities. This booklet explains the risks inherent in such conflicts and provides frameworks for managing those risks.

Note for Community Banks

This booklet applies to examinations of all national banks and FSAs (collectively, banks) that offer asset management services, including banks that have trust powers and offer fiduciary services.


Specifically, this booklet incorporates updated guidance and references related to

  • current business practices.
  • U.S. Securities and Exchange Commission requirements.
  • late trading and market timing in mutual funds and collective investment funds.
  • fiduciary purchases of securities underwritten by banks or their affiliates.
  • indenture trustees.

The issuance of this booklet makes applicable to FSAs the following OCC guidance:

  • OCC Bulletin 2008-5, “Conflicts of Interest: Risk Management Guidance—Divestiture of Certain Asset Management Businesses” (March 6, 2008)
  • OCC Bulletin 2010-37, “Fiduciary Activities of National Banks: Self-Deposit of Fiduciary Funds” (September 20, 2010)

The issuance of this booklet rescinds the following documents:

  • Trust Banking Circular 19, “Fiduciary Purchases of Bonds When Bank Participates in Underwriting Syndicates” (September 25, 1981)
  • Banking Circular 218, “Sweep Fees” (October 31, 1986)
  • Banking Circular 233, “Acceptance of Financial Benefits by Bank Trust Departments” (February 3, 1989)

For further information, contact Tish Dalton, Risk Specialist, Credit and Market Risk Division, or Joel Miller, Asset Management Group Leader, Credit and Market Risk Division, at (202) 649-6360.


Jennifer C. Kelly
Senior Deputy Comptroller and Chief National Bank Examiner

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