Is there a guideline or parameter as to what level of exceptions to policy is acceptable. I was thinking it was 10% per the OCC guidance but I cannot locate the guidance.

I can't cite a particular level, but I can tell you from experience that our examiners are looking more at the exception "process" rather than simply a number or ratio. By this I mean what is your documentation for policy exceptions? We have a process whereby all loan policy exceptions are pre-approved by the chief lending officer (if an immediate need is required) or are approved by Loan Committee. Exceptions caught after funding (post-funding exceptions) are reported to the officer who must respond back to me as to what corrective action (s)he has taken. All exceptions, pre-funding and post-funding are reported to the Board monthly. Examiners have been very complimentary of this process and have indicated that it meets all of their objectives. I can assure you that you will find your exceptions drop once you have in place some sort of monitoring process that is reported to the Board. No one likes to be on that list!