The OCC issued guidance on July 22 that clarifies the factors that examiners will consider in rating mutual federal savings associations for each component of the Uniform Financial Institutions Rating System (more commonly referred to as CAMELS). The guidance, published as OCC Bulletin 2014-35, also may be relevant for certain stock federal savings associations that are part of a mutual holding company structure.

     Nutter Notes: The guidance noted that the OCC’s rescission of OTS executive compensation guidance has created some uncertainty for federal mutual savings associations. The new guidance in very general terms clarifies the OCC’s expectations for executive compensation by federal mutual institutions, including those that might offset their inability to offer traditional equity incentives by offering alternatives such as phantom stock plans.