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FCA Examination Manual updates

The FCA Examination Manual is updated regularly to reflect changes in laws, regulations, or other examination criteria, and to address emerging risks affecting the Farm Credit System and changes to its products and services. The list below includes all updates since August 2014.​​
Date
  
Description
  
Update Details
10/24/2024EM 61.1 Interest Rate Risk
  • Updated hyperlinks to eCFR.
  • Added a reference to FCA’s stress testing IM.
  • Added additional guidance on IRR sources, market value of equity, and a System bank’s statutory collateral position.
  • Made other misc. technical and grammatical edits.
10/24/2024EM 61.2 Interest Rate Risk Management
  • Updated hyperlinks to eCFR.
  • Added a reference to the stress testing IM as well as interagency guidance on stress testing.
  • Made revisions to address guidance from FCA BL-074 and provided added clarity and guidance on market value of equity and market value of assets.
  • Added guidance to address System specific assumptions.
  • Added guidance to address additional considerations for effective governance, oversight, and reporting expectations.
  • Made other misc. technical and grammatical edits.
10/17/2024WP 33.3-1 Annual Report to Shareholders
  • Added additional guidance on UBE reporting to row 21L.
  • Revised rows 78 and 79 and former row 81 to address the new YBS regulations. Row 80 was deleted.
  • Revised former row 87 to clarify the direction in the note.
  • Made miscellaneous other technical and grammatical updates.
6/13/2024EM 51.1 Liquidity Risk
  • Updated hyperlinks to eCFR.
  • Added a reference to the stress testing IM.
  • Revised an evaluative question to focus more on statutory collateral and added additional content.
  • Made other misc. technical and grammatical edits.
6/13/2024EM 51.2 Liquidity Management
  • Updated hyperlinks to eCFR.
  • Added an evaluative question on FCA Funding Approvals for debt issuance.
  • Added guidance on intraday liquidity.
  • Added a reference to the stress testing IM as well as additional guidance on stress testing.
  • Made revisions in 2 procedures to address guidance from BL-074.
  • Added various references to statutory collateral throughout the guidance.
  • Updated the Audit procedure to be consistent with the other audit procedures in the EM.
  • Made other misc. technical and grammatical edits.
5/16/2024EM 22.3 Credit Administration
  • Updated hyperlinks to eCFR.
  • Added guidance that is more applicable to Credit Administration that will be/was moved from the Collateral Risk Management and Portfolio Planning & Analysis topics (i.e., shared asset identifier, appraisal/collateral evaluation due diligence, staffing & training, borrowing base).
  • Revised/added guidance around land in transition and essentially other than farming lending. Added guidance on IRR and liquidity risk under Direct Loan Monitoring from BL-074 and BL-072.
  • Made other misc. technical and grammatical edits.
5/16/2024EM 33.3 Financial & Shareholder Reporting
  • Updated hyperlinks to eCFR.
  • Added guidance for examining compliance with FCA Regulation 621.15 which was previously examined in the Portfolio Planning & Analysis topic.
  • Made other misc. technical and grammatical edits.
5/8/2024EM 22.1 Portfolio Planning & Analysis
  • Updated hyperlinks to eCFR.
  • Updated the structure and formatting of the procedures to reflect the standard Examination Manual (EM) structure with evaluative questions and related guidance.
  • Updated guidance in several procedures to reflect sound business practices.
  • Deleted two procedures as guidance was duplicative of guidance in other EM topics.
  • Moved some guidance content into other sections of the EM where it was a better fit.
  • Combined guidance from 5 procedures into 2 procedures.
  • Updated the Audit procedure to be consistent with the other audit procedures in the EM.
  • Made other misc. technical and grammatical edits.
5/2/2024EM 31.2 Business Strategy & Planning
  • Updated hyperlinks to eCFR.
  • Updated references and linked to new Stress Testing IM.
  • Incorporated applicable references to BL-074.
  • Updated YBS guidance to address new regulation.
  • Made other misc. technical and grammatical edits.
5/2/2024WP 31.2-4 Business Planning Regulatory Compliance
  • Updated hyperlinks to eCFR.
  • Updated YBS section to address new regulation.
  • Made other misc. technical and grammatical edits. 
4/23/2024EM 31.1 Direction & Control of Operations
  • Added new procedure titled Stress Testing Framework.
  • Added guidance on wholesale funding arrangements to the Cooperative Principles procedure.
  • Updated the UBE procedure to clarify guidance expectations and regulatory requirements.
  • Made other misc. technical and grammatical edits.
4/23/2024EM 41.2 Earnings Management
  • Updated hyperlinks to eCFR.
  • Changed all references of ‘pricing model’ to ‘pricing framework’.
  • Added an evaluative question on stress testing to the Plans & Strategies procedure.
  • Made revisions in several procedures to address guidance from FCA BL-074.
  • Made other misc. technical and grammatical edits.
3/5/2024EM-31.4 Human Capital Management
  • Added language to the topic overview and several procedures to address outsourcing human capital functions.
  • Added a reference and link to the diversity and inclusion IM in the Plan and Strategies procedure.
  • Revised links to go to the eCFR and added hyperlinks to the AAP regulations.
  • Added additional guidance in the Compensation Committee procedure to expand on considerations for committee effectiveness.
  • Removed the section on maximum bank director compensation and moved applicable content to a bank only board policy evaluative question.
  • Added a couple notes to the Employee Compensation procedure to address the incentive rules for insurance sales and not using FIRS ratings as incentive criteria.
  • Updated the Audit procedure to be consistent with the other audit procedures in the Examination Manual.
  • Made misc. other technical and grammatical changes. 
3/5/2024EM 31.5 Mission Compliance
  • Updated hyperlinks to eCFR.
  • Added reference to IM on revisiting diversity and inclusion 10 years later and added additional guidance.
  • Updated the YBS procedure to address the new regulation and revised BL-040.
  • Revised the Investments procedure to include an evaluative question on guidance and controls for investing in public mission purposes and another on RBICs.
  • Updated the Audit procedure to be consistent with the other audit procedures in the Examination Manual and added a reference to the revised BL-040.
  • Made other misc. technical and grammatical edits.
2/2/2024EM- 33.1 Federal Lending Regulations
Published new guidance for most of the procedures. Updated guidance in the following procedures for consistency in structure and to address outdated guidance, and technical and grammatical updates:
  • HMDA
  • TILA
  • RESPA
  • Margin Stock
11/17/2023WP 33.3-1 Annual Report to Shareholders
  • Added a 620.2(c) regulatory cite to the “note” sections in rows 5, 9c, and 10c.
  • Added text to more closely mirror regulatory language in rows 9d, 11, and 25j.
  • Revised language around allowance for credit losses to accurately reflect regulatory expectations in row 47b.
  • Fixed incorrect number reference to accurately reflect #104 in rows 105 and 106.
  • Made miscellaneous other technical and grammatical updates.
9/27/2023EM-1.1 Structure and Use of Manual
Updated guidance to reflect 30 Examination Manual topics, added link to Summaries of Examination Manual Updates, added language that the Examination Manual for System institutions excludes Farmer Mac, and made miscellaneous other technical and grammatical updates.
9/27/2023EM-1.2 Overview of FCA Examination Process
Updated guidance to add a section on FCA access to institution documents and records, add a new requirement for institutions to request an IRS Express Determination letter, and made miscellaneous other technical and grammatical updates.
9/26/2023WP 33.3-1 Annual Report to Shareholders
Updated guidance to remove the reference to historical capital ratios, adjust terminology to reflect the allowance for credit losses, update links to the eCFR, and made miscellaneous other technical and grammatical updates.
9/22/2023EM-31.9 Standards of Conduct, Whistleblower, & Criminal Referral
Updated guidance to provide more direction over Standards of Conduct (SOC) related benchmarks and thresholds, revise SOC Official review guidance, and clarify guidance on SOC Official investigations.  Added additional regulatory expectations for whistleblower programs, criminal referrals, and SOC audit requirements. Made miscellaneous technical and grammatical updates.
6/29/2023EM- 31.1 Direction & Control of Operations
Revised the topic name from Corporate Governance to Direction & Control of Operations. Added link to new Interagency guidance on Third-Party Risk Management. Revised FCA regulation hyperlinks to take you to the Electronic Code of Federal Regulations. Made other miscellaneous technical and grammatical updates.
6/29/2023EM-31.8 Director Elections & Qualifications
Elevated as a standalone topic (was formerly addressed as part of the Corporate Governance topic). Added an audit procedure and related guidance. No other changes were made. 
6/29/2023EM-31.9 Standards of Conduct, Whistleblower, & Criminal Referral
Elevated as a standalone topic (was formerly addressed as part of the Corporate Governance topic). Added an audit procedure and related guidance. No other changes were made.
6/22/2023EM 1.3 FIRS
  • Changed the Managing Risk Concentrations qualitative factor to Concentration Risk Management.
  • Changed the Corporate Governance qualitative factor to Direction & Control of Operations.
  • Added two new qualitative factors under the Management component, Director Elections & Qualifications and Standards of Conduct, Whistleblower, & Criminal Referral.
  • Moved criteria from the old Corporate Governance qualitative factor to the new qualitative factors and added additional criteria under the new qualitative factors.
  • Made miscellaneous technical and grammatical updates.
6/16/2023EM- 22.4 Concentration Risk Management
Published new guidance for the Concentration Risk Management topic. Additionally, WP 22.4-7 Lending (and Leasing) Limit Base Computation was rescinded.
6/14/2023High-Risk Asset Accounting and Reporting
Updated the guidance to address new CECL terminology and remove guidance related to Troubled Debt Restructures. Revised FCA regulation hyperlinks to take you to the Electronic Code of Federal Regulations. Made other miscellaneous technical and grammatical updates.
6/14/2023EM-22.2 Risk Identification
Updated the guidance to address new CECL terminology and remove guidance related to Troubled Debt Restructures. Revised FCA regulation hyperlinks to take you to the Electronic Code of Federal Regulations. Made other miscellaneous technical and grammatical updates.
5/11/2023EM 1.3 FIRS
We made miscellaneous technical and grammatical updates in addition to the following changes in the qualitative factor criteria and statistics:
  • Overview – Revised allowance for loan loss references to be allowance for credit losses.
  • Assets – Revised allowance for loan loss references to be allowance for credit losses and also added a new statistic for allowance for credit losses on debt securities. Specified the qualitative factor for Allowance for Losses qualitative factor is focused on loans and added comments to address allowance for credit losses on debt securities in the Investments qualitative factor.
  • Management – Added rating criteria around internal controls over financial reporting to the Financial & Shareholder Reporting qualitative factor.
  • Earnings – Revised provision for loan loss references to be provision for credit losses on loans and also added a new statistic for provision for credit losses on debt securities.
  • Liquidity – Added rating criteria around the banks statutory collateral margin to the Liquidity Risk qualitative factor.
1/27/2023EM-21.2 Allowance for Losses

Updated the guidance to address the new CECL requirements that were effective as of January 1, 2023. Specifically: 

  • Changed the procedure name for Policy, Procedures, Methodologies, & Controls. (It was previously named Policy, Procedures, & Controls.)
  • The Allowance Level and Policy, Procedures, Methodologies, & Controls procedures were rewritten to address the new CECL requirements.
  • The Audit and Transaction Testing procedures included minor revisions to address the new CECL requirements. 
  • Made other miscellaneous technical and grammatical updates.
1/27/2023EM- 21.3 Investments
Updated the guidance to address the new CECL requirements that were effective as of January 1, 2023. Specifically:
  • Changed the procedure name for Financial Impact. (It was previously named Accounting.)
  • Moved the examination of financial impact to the Financial Impact procedure from the Portfolio Characteristics & Trends procedure.
  • Updated the various procedures under the Investments topic to address the new CECL requirements. The majority of the revisions were in the Financial Impact procedure to address ACL processes, ACL zero-loss, ACL at acquisition, and ACL level.
  • Made other miscellaneous technical and grammatical updates.
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