Already under scrutiny by state attorneys general over sales of defaulted credit card debt, big banks now may be facing an even more pressure from the federal Office of the Comptroller of Currency. Earlier this year, the OCC began issuing its bank examiners a four-page set of "best practices" to be used in assessing banks' sales of delinquent consumer debts to third parties. The document, not yet installed formally as agency policy, reflects the OCC's position that questionable debt sales are a safety and soundness issue for banks that must be rectified. It addresses general concerns about debt collection and sales, but zeroes in on "robo-signing" of documents and incomplete records when selling soured loans to third-party collectors. Specifically, the watchdog recommends that banks verify the accuracy and completeness of all debt records that they sell; monitor how debt buyers collect on accounts and scale down their reliance on lawsuits; bar debt buyers from re-selling defaulted accounts; create a central debt sale oversight panel; provide written justifications for selling debts instead of collecting on them internally; give debt buyers key account information and make full documentation available for a nominal charge or at no cost; and separate accounts that are approaching the statute of limitations or that involve sensitive customers, including active-duty enlisted personnel and borrowers undergoing bankruptcy. "The OCC understands that consumer protection plays a very important role in a bank's safety and soundness," remarked Ira Rheingold of the National Association of Consumer Advocates. "This [debt sales to collection agencies] is an area where there is enormous heat coming."