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Exception Tracking Spreadsheet (TicklerTrax™)
Downloaded by more than 1,000 bankers. Free Excel spreadsheet to help you track missing and expiring documents for credit and loans, deposits, trusts, and more. Visualize your exception data in interactive charts and graphs. Provided by bank technology vendor, AccuSystems. Download TicklerTrax for free.

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OCC reminder on investments in venture capital funds

The OCC has issued Bulletin 2021-54 to remind OCC-supervised banks and savings associations of restrictions on most equity investments in venture capital funds. The Bulletin includes these points:

  • Banks generally may not make passive equity investments in venture capital funds.
  • Equity investments in venture capital funds may be permissible if they are public welfare investments or investments in small business investment companies.
  • Qualifying for the Volcker rule's venture capital fund exclusion does not make a fund a permissible investment for a bank.
  • As with any investment, before a bank invests in a venture capital fund, the bank must determine whether the investment is permissible and appropriate for the bank.
  • Impermissible and inappropriate investments expose the bank and its institution-affiliated parties to enforcement actions and civil money penalties.
  • National bank directors may be personally liable for impermissible investments' losses.
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