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The Secured Lender

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#3 -_ 1 (1)

December 8, 2025

Source: The Office of the Comptroller of the Currency (OCC)

The Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) (collectively, the agencies) are withdrawing from the “Interagency Guidance on Leveraged Lending” (2013 Guidance), dated March 21, 2013, and the “Frequently Asked Questions for Implementing March 2013 Interagency Guidance on Leveraged Lending” (2014 FAQs), dated November 7, 2014. The agencies expect banks to manage leveraged lending exposures consistent with general principles for safe and sound lending. The agencies are also rescinding their communications that transmitted these two documents.[1]

Note for Community Banks

The interagency statement transmitted by this bulletin applies to all OCC-supervised banks.[2]

Highlights

  • The agencies are withdrawing from the 2013 Guidance and the 2014 FAQs on leveraged lending, as well as rescinding the communications transmitting these two documents.
  • Banks that engage in leveraged lending, including purchasing a participation in a leveraged loan, are expected to manage their risks associated with leveraged lending consistent with general principles for safe and sound lending, as described further in the “Interagency Statement on OCC and FDIC Withdrawal from the Interagency Leveraged Lending Guidance Issuances.”
  • Examiners will examine banks’ underwriting, review risk ratings, and monitor the adequacy of loan loss reserves in accordance with general principles of safe and sound lending in a manner tailored to the size, complexity, and risk of leveraged lending activities.

Further Information

Please contact Barry Mills, Director for Commercial Credit Risk Policy, at (202) 649-6220 or Joanne Phillips, Counsel, or Natalie White, Special Counsel, Chief Counsel’s Office at (202) 649-5490.

James M. Gallagher

Senior Deputy Comptroller and Chief National Bank Examiner

Related Links

1 OCC Bulletin 2013-9, “Leveraged Lending: Guidance on Leveraged Lending,” and OCC Bulletin 2014-55, “Leveraged Lending: Frequently Asked Questions for Implementing March 2013 Interagency Guidance on Leveraged Lending”; FDIC FIL-53-2013, “Final Joint Guidance on Leveraged Lending,” and FDIC FIL-54-2014, “Interagency Guidance on Leveraged Lending: Frequently Asked Questions (FAQS).”

2 “Banks” refers collectively to national banks, federal savings associations, and federal branches and agencies of foreign banking organizations.