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Financial Services Law Insights and Observations

OCC Issues Updated Procedures for Termination of Federal Charters

Agency Rule-Making & Guidance Federal Issues OCC Bank Supervision Licensing Comptroller's Licensing Manual

Agency Rule-Making & Guidance

On June 7, the OCC released Bulletin OCC 2017-20 announcing a revised booklet covering termination of federal bank charters. The booklet, part of its Comptroller’s Licensing Manual, replaces “Termination of National Bank Status,” issued in April, 1998, and applies to all national banks and federal savings associations. According to the Bulletin, these are the highlights of the revised booklet:

  • “provides an overview of policy considerations and evaluative factors that the OCC considers when reviewing notices to terminate a bank”;
  • “outlines requirements and procedures that a bank should follow when completing the process to terminate, either through a merger, conversion, or liquidation, including completing related filings and notices”;
  • “lists references and links to informational resources, sample forms, and documents that a bank may find useful during the termination process”;
  • “incorporates revised regulatory requirements for terminating a bank.”

Updates include termination procedures and requirements from after July, 21 2011, when the Office of Thrift Supervision and the OCC were integrated.