Alert October 02, 2012

OCC Issues Supervisory Guidance on Rental Properties

The OCC issued supervisory guidance on the risk management and reporting requirements for rental properties. The guidance bulletin is applicable to investor-owned, one- to four-family residential real estate lending where the primary repayment source for the loan is rental income. The guidance requires that banks have credit risk management policies and processes for the risks specific to investor-owned, one-to four family residential real estate lending that cover, among other things, underwriting and loan identification and portfolio monitoring expectations.