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Update: When Are Section 19 Application Required?
On November 1, 2018, the Federal Deposit Insurance Corporation (the “FDIC”) issued modifications to its Statement of Policy (“SOP”) for applications made under Section 19 of the Federal Deposit Insurance Act (“FDIA”). The modifications are expected to reduce the number of Section 19 applications FDIC-supervised institutions must submit prior to submitting offers of employment.
Background
On January 8, 2018, the FDIC published in the Federal Register notice of proposed modifications and sought public comment. On July 19, 2018, after consideration of comments received, the FDIC approved modifications to the SOP’s exceptions to filing an application and made additional technical and clarifying changes.
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Regulatory Relief Continues: Federal Banking Agencies Propose New Capital Relief Rules for Large Banking Organizations
On October 31, 2018, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Office of the Comptroller of the Currency (the “OCC”) and the Federal Deposit Insurance Corporation (the “FDIC”) issued a pair of proposals that would more closely match the regulations for large banking organizations, or banks with more than $100 billion in total consolidated assets, with their risk profiles. Continue Reading Regulatory Relief Continues: Federal Banking Agencies Propose New Capital Relief Rules for Large Banking Organizations
Regulatory Alert: Federal Regulators Issues New FAQs on Appraisal and Evaluation
On October 16, 2018, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation and the Board of Governors of the Federal Reserve System (the “Agencies”) issued the Frequently Asked Questions on appraisal and evaluation functions (“FAQs”). Continue Reading Regulatory Alert: Federal Regulators Issues New FAQs on Appraisal and Evaluation
Bringing a Level of Clarity to the Interagency Biographical and Financial Report
On July 11, 2018, the Office of the Comptroller of the Currency (“OCC”), the Federal Deposit Insurance Corporation (“FDIC”) and the Board of Governors of the Federal Reserve System (“FRB”) (the OCC, FRB and FDIC are collectively, the “Federal Banking Agencies”) issued revisions to the Interagency Biographical and Financial Report (the “Report”).
In general, individual directors, officers, or an individual or group of shareholders acting in concert that will own or control 10 percent (10%) or more of a bank must file the Report in connection with the following: (i) applications to establish a de novo bank, (ii) notices for a change in control, (iii) Section 914 applications for new executive officers and directors, and (iv) applications for new executive officers and directors following a change in control.
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