On May 4, BPI submitted a letter to the Office of the Comptroller of the Currency in response to the agency’s request for comment on the OCC’s rules relating to policies and procedures for corporate activities involving national banks and federal savings associations in 12 C.F.R. Part 5. BPI generally supports the OCC’s proposed changes, which are intended to update and clarify policies and procedures, eliminate unnecessary requirements consistent with safety and soundness, and make other technical and conforming changes.
In particular, the comment letter agrees with the OCC’s proposals that would reduce regulatory burden for national bank branch relocations, OCC review of business combinations and filings related to operating subsidiaries and equity investments of national banks, among other things. Consistent with BPI advocacy, the letter also argues that the OCC should reform the use of “well managed” status which serves as an eligibility requirement for various regulatory approvals. The letter specifically recommends conforming eligibility and review criteria under Part 5 to a single standard, except as otherwise required under applicable law, that takes into account the safety and soundness criteria that are most relevant to the activity at hand and that is not conditioned on any single CAMELS component rating (such as a Management) or a consumer compliance rating of at least 2.
