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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

IL=Interpretive Letter

OCC Bulletin 1998-32, “Civil Money Penalties: Interagency Statement” (July 24, 1998)

OCC Bulletin 2006-24, “Interagency Agreement on ERISA Referrals: Information Sharing Between the FFIEC Agencies and the DOL” (June 1, 2006)

OCC Bulletin 2007-7, “Soft Dollar Guidance: Use of Commission Payments by Fiduciaries”   (February 5, 2007)

OCC Bulletin 2008-5, “Conflicts of Interest: Risk Management Guidance—Divestiture of Certain Asset Management Businesses” (March 6, 2008)

OCC Bulletin 2010-24, “Incentive Compensation: Interagency Guidance on Sound Incentive Compensation Policies” (June 30, 2010)

OCC Bulletin 2010-37, “Fiduciary Activities of National Banks: Self-Deposit of Fiduciary Funds” (September 20, 2010)

OCC Bulletin 2013-29, “Third-Party Relationships: Risk Management Guidance” (October 30, 2013)

OCC Bulletin 2015-3, “Conflicts of Interest: Revised Comptroller's Handbook Booklet and Rescissions” (January 14, 2015)

Related News and Issuances
Publish DateIdentifierTitle
03/18/2015  NR 2015-37, Comptroller of the Currency Issues Statement Regarding Bank Investment in the Municipal Securities Market
03/06/2008  OCC 2008-5, Conflicts of Interest: Risk Management Guidance – Divestiture of Certain Asset Management Businesses