The OCC, FRB, and FDIC issued guidance
on leveraged lending, setting forth high-level principles related
to safe and sound leveraged lending activities, including
underwriting considerations, assessing and documenting enterprise
value, risk management expectations for credits awaiting
distribution, stress testing expectations and portfolio management,
and risk management expectations. All financial institutions should
have the capacity to properly evaluate and monitor underwritten
credit risks, to understand the effect of changes in borrowers'
enterprise values upon credit portfolio quality, and to assess the
sensitivity of future credit losses to changes in enterprise
values. Under the guidance, institutions should have: (i)
underwriting policies for leveraged lending, including
stress-testing procedures for leveraged credits; (ii) risk
management policies, including stress testing procedures for
pipeline exposures; and (iii) policies and procedures for
incorporating the results of leveraged credit and pipeline stress
tests into the firm's overall stress-testing framework.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.