Reed Smith Client Alerts

Delivering a much-anticipated Christmas package, on December 22, 2020, the Office of the Comptroller of the Currency (OCC) published an expansive series of revised regulations governing the activities and operations of national banks and federal savings associations. In simplest terms, this final rule amends Part 7 of OCC regulations to clarify and codify recent OCC interpretations, integrate an array of national bank and federal savings association regulations, and update or eliminate outdated regulatory requirements to align with the present-day banking system. The OCC expects these changes will help promote economic growth for consumers, businesses and communities.

Part 7 is important to virtually all banks and thrifts in two principal respects. First, it further levels the playing field by extending a substantial number national bank powers to federal savings associations. Second, the activities permitted for national banks and federal savings associations have long stood as the benchmark by which state and federal banking laws authorize activities permissible for state-chartered institutions.

While Part 7 originated as a convenient codification of interpretive rulings, it has evolved into a formal regulation carrying the full force of law. In this latest iteration, for the first time the OCC introduces Subpart A (Powers) of Part 7 with a new § 7.1000 that provides a framework for all powers that follow.