Topic: Other Real Estate Owned (OREO)
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Has there been any recent regulatory guidance (within the past few months) warning against innovative OREO strategies?
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We are aware of one example of regulatory guidance on OREO, and while we are not aware of others offhand, there may be more: In 2011, both the Federal Reserve and the OCC published letters on the use of asset-exchanges by smaller community banks. They explain that banks are starting to dispose of nonperforming assets…