In our last exam, ending in 2005, we had some regional prior period investments. Our examiner put them on our Table 14 in proportion to our deposits in each market. During our recent exam, I was given a Table 14 to review where these investments were handled in the same way. However, when our final PE was received, it showed no prior period investments. When I asked our examiner, he said that they had changed the way they reported regional investments and no longer allocated them according to deposits. He did, however, mention them in the narrative of the exam.

Two questions, (1) Have other OCC examined banks been given the same treatment for prior period regional investments, and (2) How do other CRA professionals feel about the fact that the OCC has so many internal policy changes that effect us, that we have no way of knowing about until the actual exam?