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BankNet
More resources for national banks

Conflicts of Interest

Banks providing asset management services may encounter a variety of actual or potential conflicts of interest. Banks acting as fiduciaries must put the interests of account beneficiaries before the interests of the bank.

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Conflicts of Interest (Comptroller’s Handbook, January 2015)
Provides examiner guidance for evaluating risk management practices in place to control conflicts of interest and self-dealing

References
IL=Interpretive Letter
OCC=Bulletin

Banks/Thrifts Providing Financial Support to Funds Advised by the Banking Organization or its Affiliates (OCC 2004-2, January 2004)
Covers safety, soundness, and legal issues for banks providing financial support to investment funds advised by the bank, its subsidiaries, or affiliates

Conflicts of Interest: Risk Management Guidance-Divestiture of Certain Asset Management Businesses (OCC 2008-5, March 2008)
Covers conflicts of interest in the sale of an affiliated mutual fund complex or its associated investment adviser to unaffiliated parties

Fiduciary Activities of National Banks: Self-Deposit of Fiduciary Funds (OCC 2010-37, September 2010)

Reporting of Personal Transactions in Securities (IL 1062, April 2006)
Covers national banks’ request to increase the personal transactions reporting period pursuant to 12 CFR 12.7 (a) (4)

Soft Dollar Guidance: Use of Commission Payments by Fiduciaries (OCC 2007-7, February 2007)
Covers the analytical framework, eligibility criteria, and commission-sharing arrangements associated with commission payments by fiduciaries


Related News and Issuances
Publish DateIdentifierTitle
03/06/2008  OCC 2008-5, Conflicts of Interest: Risk Management Guidance – Divestiture of Certain Asset Management Businesses