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?
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…