Archive

TEMPORARY ASSET THRESHOLDS

On December 2, 2020 the Office of the Comptroller of the Currency, the Federal Reserve Board of Governors, and the Federal Deposit Insurance Corporation (collectively the Agencies) published an interim final regulation (IFR) to mitigate temporary transition costs on banking organizations related to the coronavirus disease 2019 (COVID event), by issuing an interim final rule to permit national banks, savings associations, state banks, bank holding companies, savings and loan holding companies, and U.S. branches and […]

INTERAGENCY STATEMENT – CEASE ORIGINATION OF LIBOR-BASED CONTRACTS

On November 30, 2020, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the agencies) issued a statement to encourage banks to cease entering into new contracts that use USD LIBOR as a reference rate as soon as practicable and in any event by December 31, 2021, in order to facilitate an orderly—and safe and sound— LIBOR transition.

INTERAGENCY STATEMENT ON LIBOR TRANSITION

On November 6, 2020, the Comptroller of the Currency, the Federal Reserve Board and the Federal Deposit Insurance Corporation (collectively, the agencies) issued a Statement on Reference Rates for Loans. The statement reiterates that the agencies are not endorsing a specific replacement rate for LIBOR for loans. A bank may use any reference rate for its loans that the bank determines to be appropriate for its funding model and customer needs. However, the bank should […]

FRB ISSUES ANPR FOR CRA

On September 21, 2020, the Federal Reserve Board of Governors (FRB) released an Advanced Notice of Proposed Rulemaking (ANPR) that starts the process of revising the FRB’s Regulation BB, which implements the Community Reinvestment Act for state member banks. The ANPR has a 120-day comment period that begins once the ANPR is published in the Federal Register. The FRB’s ANPR stands in contrast to the final CRA regulations published by the Office of the Comptroller […]

ARE REGULATORS RENEGING ON CRA PROMISES?

On March 19, 2020, the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the agencies) published a Joint Statement of Policy (SOP) promising favorable consideration of retail banking services and retail lending activities in a financial institution’s assessment areas that are responsive to the needs of low- and moderate-income individuals, small businesses, and small farms affected […]