Washington, D.C. – BPI, the American Bankers Association and the Independent Community Bankers of America sent a joint comment letter calling on the OCC to withdraw its Notice of Proposed Rulemaking on National Bank and Federal Savings Association Premises. The proposal would abandon a flexible, principles-based approach to regulating what banks can do with their buildings, land and facilities that has worked well for decades, and instead adopt a bright-line, rules-based approach. The lack of flexibility in the proposal would diminish the ability of banks to adapt to the post-pandemic transformation of work and business environments as well as other changing circumstances in the future.
“In any case, as they consider changes to space needs and use, banks need flexibility to adapt to an uncertain future,” the groups said in the comment letter. “Implementing the Proposal now would interfere with banks’ ability to adapt to changing premises needs and arrangements in a post-pandemic working environment, detracting from their ability to hire competitively.”
Bank Policy Institute
American Bankers Association