OCC 2002-20
OCC Bulletin
Subject:     Implicit Recourse in Asset Securitization
Description: Policy Implementation
Date:        May 23, 2002

TO:  Chief Executive Officers of All National Banks, 
     Department and Division Heads, and All Examining 
     Personnel


The attached "Interagency Guidance on Implicit Recourse 
in Asset Securitizations" was issued jointly by the 
Office of the Comptroller of the Currency, the Board of 
Governors of the Federal Reserve System, the Federal 
Deposit Insurance Corporation, and the Office of Thrift 
Supervision on May 23, 2002.  The purpose of this guidance 
is to assist both bankers and examiners in assessing what 
types of post-sale actions may, or may not, constitute 
implicit recourse.  However, the ultimate decision 
regarding risk-based capital treatment for these actions 
rests with the institution's primary regulator. 

The attached statement highlights several examples of 
post-sale actions taken by institutions with respect to 
securitized assets.  Examiners and bankers should be 
aware that, depending upon the specific circumstances, 
such actions could result in additional risk-based capital 
requirements.

For further guidance on recourse and asset securitization 
issues contact Amrit Sekhon, Capital Policy at (202) 
874-5211, or Greg Coleman, Treasury and Market Risk at 
(202) 874-2777.




________________________		__________________
Michael L. Brosnan			Tommy Snow
Deputy Comptroller for			Director for
Risk Evaluation				Capital Policy



Attachment
[ http://www.occ.treas.gov/ftp/bulletin/2002-20a.pdf ]