Compliance Bulletin

New OCC Handbook Regulates Deposit Related Credit
March 2, 2015

Without affording national banks and federal saving associations an opportunity to offer comments, the Office of the Comptroller of the Currency issued revisions to its handbook affecting credit-related to deposit accounts. The Handbook applies immediately to new accounts and existing accounts and does not distinguish between consumers and business customers. Since this change is not matched by the other federal banking agencies, national banks and federal savings associations face disparate regulatory treatment. For more information, please see CBA’s Regulatory Compliance Bulletin prepared by Ted Kitada, senior counsel with Wells Fargo Bank and chairman of CBA’s Legal Affairs Committee.