OCC confirms permissibility of personal guarantee insurance for national banks

OCC Interpretive Letter No. 1194 provides important regulatory clarity for personal guarantee insurance and the bank-owned insurance structure underlying AuFort's proprietary BOGI™ program.

On September 3, 2026, the Office of the Comptroller of the Currency (OCC) issued Interpretive Letter No. 1194, concluding that personal guarantee insurance (PGI) qualifies as an authorized credit-related insurance product that national banks may provide in connection with commercial lending.

The decision establishes an important regulatory foundation for bank-owned personal guarantee insurance programs, including the structure underlying AuFort's Bank-Owned Guarantee Insurance™ (BOGI™).

What the OCC decision means for commercial banks

Personal guarantees are a standard component of commercial lending, yet they can create significant exposure for borrowers while providing uncertain recovery for lenders following a default.

Personal guarantee insurance addresses this imbalance by providing insurance protection tied to a guarantor's financial obligations.

The OCC's interpretation recognizes PGI as a form of credit-related insurance under existing federal banking law, confirming its permissibility for national banks within the circumstances reviewed.

For financial institutions evaluating additional tools to manage commercial credit risk, the decision provides greater regulatory clarity around the use of personal guarantee insurance.

Implications for AuFort's BOGI™ program

AuFort's proprietary, patent-pending BOGI™ program is designed to integrate personal guarantee insurance with a bank-owned reinsurance structure.

Under this model, an independent insurance carrier issues coverage to eligible commercial borrowers, while a bank-owned subsidiary participates in reinsuring the associated risk.

The program is designed to support stronger credit recovery, enhance borrower relationships, and provide banks with an additional mechanism for managing risk within established commercial lending frameworks.

The OCC's interpretation provides a significant regulatory foundation for this approach, subject to the facts and circumstances of the applicable program.

Read the OCC interpretive letter

The OCC's full decision is publicly available as Interpretive Letter No. 1194, dated September 3, 2026.

Read OCC Interpretive Letter No. 1194→

To learn more about AuFort's Bank-Owned Guarantee Insurance™ program, visit AuFort for banks→.

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