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Financial Services Law Insights and Observations

OCC releases additional guidance on state loan-to-deposit ratios

Agency Rule-Making & Guidance OCC Federal Reserve FDIC

Agency Rule-Making & Guidance

On July 25, the OCC issued Bulletin 2018-21 to provide additional guidance for covered national banks on how state loan-to-deposit ratios are used to determine compliance with Section 109 of the Riegle-Neal Interstate Banking and Branching Efficiency Act of 1994. On June 21, the Federal Reserve, the FDIC, and the OCC released the host state loan-to-deposit ratios for each state or U.S. territory. Section 109, which prohibits banks from establishing or acquiring interstate branches for the primary purpose of deposit production, requires a comparison of a bank’s statewide loan-to-deposit ratio to the yearly host state loan-to-deposit ratios. If a bank’s statewide ratio is less than one-half the yearly published host state ratio, an additional review is required by the appropriate agency.