September 20, 2018

On September 10, 2018, the Office of the Comptroller of the Currency (the “OCC”) issued a proposed rule implementing Section 206 of the Economic Growth, Relief and Consumer Protection Act, which permits federal savings associations with total consolidated assets of $20 billion or less as of December 31, 2017 to elect to operate with national bank powers without converting to a national bank charter. This election would allow an eligible federal savings association to exceed its statutory commercial and consumer lending limits and avoid compliance with the qualified thrift lender test.

For more information, including a summary of the OCC’s proposed rule, please see the attached News Alert.

View PDF