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Expert Analysis

Are OCC's Reserve-Based Lending Guidelines Enforceable?

By Buddy Clark (June 27, 2018, 1:04 PM EDT) -- Two years ago, right after crude oil prices hit rock bottom in the middle of the worst downturn for U.S. producers since the 1980s, the Office of the Comptroller of the Currency revised its Handbook for Examination of Oil and Gas Exploration and Production Lending (E&P handbook). The E&P Handbook introduced new metrics by which bank examiners were supposed to evaluate the repayment risks on banks' loans secured by oil and gas reserves, or RBLs. The changes announced by the OCC added to the angst and consternation among energy lenders and their oil and gas borrowers....

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