On June 28, BPI submitted a comment letter on the OCC’s advanced notice of proposed rulemaking (ANPR) exploring an update to the definition of “fiduciary capacity” to include directed trust-related activities and the issuance of a new regulatory framework establishing basic requirements for non-fiduciary custody activities of national banks. The letter urges against the OCC’s adoption of either contemplated rulemaking, arguing that they are unnecessary and could be counterproductive, without meaningful improvements in the OCC’s supervision of the services or benefits that bank customers receive from them.
BPI Comments on OCC’s Anticipated Rulemakings on Fiduciary Capacity and Non-Fiduciary Custody Activities
