We have recently become aware that the OCC is reviewing national bank TARP recipients for their compliance with TARP requirements as part of the formal examination process.  As of part of the examination, the OCC is requesting to review certain documents, policies, and other information related to areas impacted by the TARP regulations.  In particular, the OCC will review a TARP recipient’s Luxury Expenditure Policy, as well as other compensation-related information.

We have suspected that TARP recipients would be examined by their federal regulators for TARP compliance, and we are now seeing the first signs in formal examinations.  TARP recipients who have not already done so should take steps to ensure that they can document their compliance with the TARP requirements.

If you would like to further discuss compliance with the TARP requirements, please contact any of the attorneys in the Bryan Cave Financial Institution Group.