I am looking for the elusive "MLR" Report. It is a risk assessment report that gets sent to the OCC. I have never seen one, so as of right now it is merely speculation.

I haven't seen it this year yet. I wonder if they are still doing it or if it's been discontinued?? I think the notice would have been out by now.

http://www.bankersonline.com/forum/ubbthreads.php?ubb=showflat&Number=1341286&page=1

A previous thread

The OCC solicited comments on this system in January 2010 and officially sent the information collection program to OMB for review. The problem was that they never received OMB approval to gather such information (who audits their processes I wonder)? There has been no further word whether OMB approved the information gathering on a go forward basis.

Well, that is interesting, Randy....

I received an email this morning from the OCC checking to see if I'm this year's MLR contact person for my banks. I guess the report will follow soon.

Oh joy!!

I got a call today from OCC verifying contact information. They told me the info would go out to banks in the next few weeks.

Well, if you get to see the form, let us know if it has a OMB number assigned to it. Otherwise, it technically remains an unapproved gathering of data. Although I probably would not recommend calling them on it.

I hate this process! We have not received notification from OCC yet regarding this year's submission. The information is typically as of 9/30 of each year and we usually receive the information well in advance. Examiners are on site now, but I amy laying low until they start looking at BSA. Maybe I will ask then unless something comes out in the meantime.

We got contacted as well... no form yet, but I bet it is coming.

I think the process needs improved because the way they want data rounded up in every case, can lead to serious overstatements for average daily volumes...

Just my .02

Received my official email request yesterday with forms attached. Then today I received another email saying that there was a problem with the MLR form and they will be correcting it.

Make room for it on your calendar.

I agree with that! It can make for huge overstatements.

My recollection is that the OCC obtained "emergency" approval for gathering the information. Okay, there are five federal functional regulatory agencies. Only one of them thought gathering the information was necessary, but that one thought it was an emergency? Banks did not have a meaningful opportunity to comment then and they have not exercised their rights in the interim.

From conversations at the time it was clear the OCC thought the other agencies would see the genius in this exercise and follow suit. None did. Is the information generated valuable? To the bank, yes, but not in proportion to the amount of work involved.

Can it be cost justified by its value to the OCC? I sincerely doubt it. From a 2007 speech from the Comptroller:

Let me now share with you some important specific observations from the data. First, according to our MLR metrics, the vast majority of OCC’s community national banks are considered low risk; specifically, 89 percent are low risk; seven percent are moderate risk; and only four percent are high risk.

So, it makes sense to gather data from 100% so you can identify the 11% that are not low risk?

Pet peeve...

Just got one of my MLRs, plus info on confernece calls etc. I could cry!!!
BTW Randy there is an OMB number.

OMB 1557-0231
"The OCC estimates that it will take respondents 6 hours to complete this form."

Yea, 6 hours to complete the form, what about the time it takes to gather the information? Someone needs a wake-up call.

GGGRRRR.

I have never seen a single government time estimate that was accurate.

well, at first glance i noticed they aren't requiring that we report the number of CTR's and SAR's filed. they finally must've figured it out that they can get that information elsewhere.