On September 12, 2018, the Office of the Comptroller of the Currency (the “OCC“) released its first update to the “Deposit-Related Credit” booklet of the Comptroller’s Handbook (the “DRC Booklet“) since its March 2015 release.  (The OCC initially released a widely-critiqued DRC Booklet in February of 2015 as a replacement to its “Credit Check” booklet, but this release was quickly withdrawn.) … Continue Reading