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Wednesday, September 3, 2014

ABA: OCC Licensing Integration Imposes New Requirements

The OCC’s proposal to integrate the agency’s licensing rules for national banks and federal savings associations goes beyond integration by imposing new requirements, ABA said in a comment letter. In integrating rules, the proposal often chooses the more burdensome approach, ABA added.

For example, the OCC would create a new requirement for an application for acquisitions if a purchase-and-assumption transaction would increase the size of an institution by a quarter or more. ABA said:

Neither national banks nor thrifts were subject to such a requirement before this proposal was released. This is a substantive new requirement.

The 500-page proposal — part of the OCC's continuing process of reviewing national bank and thrift rules to determine whether it is appropriate to integrate them — makes changes to policies and procedures for both bank types related to new charters, conversions, mergers, branching, subsidiaries and other licensing issues.

Read the letter.

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