The office of the Comptroller of the Currency, Treasury (“OCC”), Office of Thrift Supervision, Treasury (“OTS”), Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”) and Securities and Exchange Commission (“SEC”) have adopted an interagency final statement on sound practices for national banks, state banks, banking holding companies (excluding foreign banks), federal and state savings associations, savings and loan holding companies, U.S. branches and agencies of foreign banks, and SEC-registered broker-dealers and investment advisers (“financial institutions”) that engage in complex structured finance transactions (“CSFTs”).  Effective Jan. 11, 2007, the final statement was adopted as supervisory guidance by the OCC, OTS, FRB and FDIC, and as a policy statement by the SEC, and is intended to describe internal controls and risk management procedures which can assist financial institutions in identifying, managing and addressing heightened reputational and legal risks that may arise from CSFTs that may be considered to have an “elevated risk.” 

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