The OCC plans to issue guidance reiterating its expectationsfor risk management for banks with foreign correspondent accounts, according toremarks made by Comptroller of the Currency Thomas Curry.
The guidance will cover best practices for conducting riskevaluations, including recommendations for effective governance to help banksre-evaluate risk and monitor recommendations regarding retention or terminationof such accounts.
In addition, it will suggest that banks have a communicationprocess wherein decisions are regularly conveyed to senior managementconcerning keeping or terminating foreign correspondent accounts, with a focuson how account closures may negatively impact access to financial services on aregional level or for an entire group of customers.
Furthermore, the agency noted that banks following bestpractices, while deciding about withdrawing from an account, have open lines ofcommunication with their foreign correspondent customers. They also considerinformation provided by customers that might help mitigate the risk.
If a bank decides to terminate such a relationship, itshould usually wait for customers to establish alternative banking relationships,unless a delay imposes additional risk. Such banks also have clear audit trialsin place that cover reasons and approaches used to close accounts.