Discussion / In Reviewing OCC Bulletin 2000-20, Which Mostly Deals With Loan Classification And The

Posted By: obrienmj

Question:

In reviewing OCC bulletin 2000-20, which mostly deals with loan classification and the timing of charge-offs, we are unsure about the use of specific reserves on loans. We are a thrift saings & loan, formerly OTS regulated, and us specific reserves (i.e. not charge-offs) when necessary. The bulletin addresses this in a little carve out section for OTS, but is this still applicable? Can we still use specific reserves, or should we be following the rest of the guidance and charging these amounts off?