ICBA told the OCC that it supports expanding flexibility for federal savings associations, but expressed concerns with a provision of the agency’s proposed rule on who is eligible. The proposal would implement an ICBA-advocated provision of the S. 2155 regulatory relief law allowing federal savings associations with $20 billion or less in assets to operate with the same rights as a national bank without applying for a national bank charter.
ICBA’s concern is with the OCC’s plan to provide eligibility to those with $20 billion or less as of Dec. 31, 2017. In its comment letter, ICBA said Congress did not intend to limit the ability of de novo federal savings associations to take advantage of this policy. ICBA asked the OCC to reconsider this provision.
Read ICBA Comment Letter
View Matrix on S. 2155 Implementation