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Post-Purchase Risk Management

Interagency Statement on the Purchase and Risk Management of Life Insurance

OCC 2004-56 (December 7, 2004)

Risk management review should include, but not necessarily be limited to:

• Comprehensive assessment of the following specific risks:
Reputation Risk Compliance/Legal Risk
Liquidity Risk Price Risk
Credit Risk Transaction/Operational Risk
Interest Rate Risk
• Identification of which employees are, or will be, insured
• Assessment of death benefit amounts relative to employee salaries
• Calculation of the percentage of insured persons still employed by the institution
• Evaluation of the material changes to BOLI risk management policies
• Assessment of the effects of policy exchanges
• Evaluation of material findings from internal and external audits and independent risk management reviews
• Identification of the reasons for, and tax implications of, any policy surrenders
• Analysis of Peer Group Holdings

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