On October 3, 2024, the OCC issued a bulletin to provide banks with guidance for managing credit risk associated with refinance risk. The bulletin applies to all banks with commercial loans and does not address other risks, such as interest rate risk.

Refinance risk is the risk that borrowers will not be able to replace existing debt at a future date under reasonable terms and prevailing market conditions. The bulletin discusses the effect of refinance risk on credit risk in commercial loan transactions and portfolios and provides guidance on transaction and portfolio-level refinance risk management.

The Bulletin can be found here.

Adam Witmer

Adam Witmer is a speaker, author, and founder of the Compliance Cohort. Adam has taught hundreds of seminars and training sessions to thousands of bankers throughout the United States and teaches on all areas of regulatory compliance. Adam has written five e-books that he never published, hit a grizzly bear while driving in a National Park, and is an award winning photographer and musician (though he no longer takes photos nor plays any instruments). In his spare time, Adam can be found kayaking on the lake, doing taekwondo with his kids, working on his (project) house, or spending time with his family.

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