The environmental risk program should provide for staff training, set environmental policy guidelines and procedures, require an environmental review or analysis during the application process, include loan documentation standards, and establish appropriate environmental risk assessment safeguards in loan workout situations and foreclosures. Examination Procedures Examiners should review an institution’s environmental risk program as part of the examination of its lending and investment activities. When analyzing individual credits, examiners should review the institution’s compliance with its own environmental risk program. Failure to establish or comply with an appropriate environmental program should be criticized and corrective action required.
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