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Legislation & Regulation


The Commercial Finance Association monitors legislation and regulation that could affect asset-based lending and factoring. Where necessary, CFA’s Advocacy Committee develops and oversees the Association’s strategy to address the issues raised in legislative and regulatory proposals. Below is a summary of the latest developments in pending legislation and regulatory initiatives of interest to secured lenders. 

OCC Releases Asset Based Lending Handbook to Guide Examiners Assessment of ABL

On March 27, 2014, the Office of the Comptroller of the Currency (OCC) released its Comptrollers Handbook on Asset Based Lending. The booklet provides guidance to examiners and bankers regarding ABL activities and risks, prudent credit risk management and underwriting expectations, credit administration, and credit risk rating. Risk-based expanded examination procedures are provided to guide ABL examinations. Expanded topics include ABL structures, credit analysis, evaluating borrower liquidity, establishing a borrowing base and prudent advance rates, collateral controls and monitoring systems, and credit risk rating considerations. The booklet also includes transaction examples to guide examiners and bankers in the assessment of credit risk.
The 78 page ABL Handbook replaces the Accounts Receivable and Inventory Financing booklet of the Comptroller’s Handbook, issued in March 2000, and replaces ABL guidance in section 214, “Other Commercial Lending,” issued in October 2009 as part of the Office of Thrift Supervision’s (OTS) Examination Handbook.

The OCC declined CFA’s offer to provide input during the drafting process but has requested that feedback on the final version be solicited from CFA members. CFA’s Advocacy Committee is collecting feedback from all CFA members. The Advocacy Committee’s OCC & Regulatory Affairs Subcommittee will synthesize the comments collected and provide feedback to the OCC as requested.
To access the ABL Handbook, click here.