On June 4, the OCC published a proposal to update rules applicable to the activities and operations of national banks and Federal savings associations.
The proposal would clarify and codify several long-standing OCC interpretations—most notably covering derivative activities, tax equity finance transactions and payment systems memberships—and update or eliminate certain outdated regulatory requirements. The proposal would also more clearly delineate roles for OCC examination staff and legal staff. Furthermore, the proposal would reform activity and governance regulations for national banks that may be considering simplification of their structures through, for example, shedding their holding companies. Finally, the proposal would integrate some regulations for national banks and Federal savings associations.
Simultaneously with the Proposal, the OCC released an ANPR requesting comment on expanding, updating and improving the regulations and interpretations on digital and electronic activities.
Comments on the proposal and ANPR are requested by August 3.
This memorandum sets out a summary of, and our observations on, the proposal, including key areas in which the OCC has requested comment.