Today, the OCC responded to a letter requesting that it offer guidance on the ability of banks to provide workout programs for distressed credit card holders. Specifically these workout programs would permit distressed borrowers to pay a lesser amount than owed over a period of time, and defer the loss recognition and income reporting. In the letter, the OCC encouraged national banks to assist distressed borrowers, and suggested exploring existing regulatory tools and programs. However, it expressed unwillingness to approve initiatives that would defer timely reporting of losses, fearing, that given the current financial climate, such programs compromise “the integrity and transparency of financial statement reporting and public confidence in the banking system.”