Retail Nondeposit Investment Products: Exam Procedures for Community Banks

Summary

The Office of the Comptroller of the Currency (OCC) will no longer examine community banks¹ using the procedures and standards in the “Retail Nondeposit Investment Products” (RNDIP) booklet of the Comptroller’s Handbook. Community banks are still expected to follow all laws and regulations applicable to their RNDIP offerings and comply with all pertinent legal requirements.

Highlights

• Many banks recommend or sell RNDIPs either to retail customers directly or more commonly through arrangements with affiliated or unaffiliated third parties.
• The OCC has published guidance to examiners regarding the examination of bank RNDIP programs in the RNDIP booklet of the Comptroller’s Handbook.
• The RNDIP booklet defines RNDIPs to include any product with an investment component that, in most instances, is not insured by the Federal Deposit Insurance Corporation. Common RNDIPs include mutual funds, exchange traded funds, variable and fixed rate annuities, equities, and fixed income securities.
• The RNDIP booklet provides comprehensive guidance for bank examiners on activities involving the recommendation or sale of RNDIPs to retail customers, explains the risks inherent in banks’ RNDIP sales programs, and provides a framework for banks to manage those risks. This booklet provides expanded examination procedures for evaluating banks’ RNDIP sales activities that supplement the core assessment standards in the “Large Bank Supervision” and “Community Bank Supervision” booklets of the Comptroller’s Handbook.
• Because of their complexity, the comprehensive exam procedures and risk management practices outlined in the RNDIP booklet are generally unsuitable for community banks. As a result, these procedures and practices impose unnecessary burden.
• The OCC makes judicious use of its exam resources and prioritizes its examinations around the most salient risks to its banks. Examining community banks according to the expanded procedures in the RNDIP booklet is not a prudent use of OCC examination resources.
• Community banks tend to have more limited RNDIP offerings. Thus, under the OCC’s risk-based examination posture, a simpler examination framework is appropriate for them. Relieving unnecessary examination burden from the RNDIP programs will leave community banks with more resources to focus on material financial risk mitigation.
• Removing unnecessary impediments to community banks’ offering of RNDIP sales programs can promote the competitive viability of community banks and the availability of beneficial financial services to consumers.
• The OCC will no longer examine community banks’ direct or indirect offering of RNDIP products using the standards and procedures in the RNDIP booklet. Instead, OCC examiners will only use the core assessment standards in the “Community Bank Supervision” booklet of the Comptroller’s Handbook.
• This change to examination policy is part of the OCC’s ongoing efforts to reflect a tailored regulatory framework for bank supervision.
• Community banks must comply with all laws and regulations applicable to their direct or indirect offering of RNDIP products and activities, including: the Gramm–Leach–Bliley Act, federal securities laws, federal and state insurance laws, consumer privacy laws, Bank Secrecy Act/anti-money laundering laws, and prudential OCC regulations.
• The OCC will continue to consider each bank’s RNDIP activities on an individual basis and will continue to consider each bank’s unique circumstances and risk profile when determining examination priorities for that institution.
• The OCC will continue to evaluate the appropriateness of the procedures and expectations in the RNDIP booklet and will consider making further edits to the booklet in the future consistent with safety and soundness principles to reduce burden for a wider range of banks.

Further Information

Please contact Chizoba N. Egbuonu, Director for Asset Management, or Rebecca Monroe, National Bank Examiner, Asset Management, the Office of the Chief National Bank Examiner, at (202) 649-6360.

James M. Gallagher
Senior Deputy Comptroller and Chief National Bank Examiner

Related Links

• “Retail Nondeposit Investment Products”
• “Community Bank Supervision”
• News Release 2025-89, “OCC Announces Updates to Organizational Structure”