Tag Archives: Home Owners’ Loan Act

OCC Interpretation Paves Way for Banks to Custody Cryptocurrency

Today, the OCC released an interpretive letter concluding that national banks and federal savings associations (together, “banks”) may permissibly provide cryptocurrency custody services for customers.  The letter, written by Chief Counsel Jonathan Gould, describes custody of cryptocurrency as a modern form of the traditional banking activity of providing safekeeping and custody services, which the agency … Continue Reading

Federal Reserve Board Announces Six-Month Delay of Effective Date of Control Framework

Yesterday, March 31, 2020, the Board of Governors of the Federal Reserve System (the “Board”) announced a six-month delay in the effective date of its final rule implementing a revised control framework.  Previously, in January, the Board unanimously approved a final rule establishing a comprehensive, simplified framework for determining when an investor company exhibits control … Continue Reading

Federal Reserve Finalizes Comprehensive Framework for Determining “Control”

On January 30, 2020, the Board of Governors of the Federal Reserve System unanimously approved a final rule that establishes a comprehensive framework for determining whether a company controls another company for purposes of the Bank Holding Company Act and Home Owners’ Loan Act, and clarifies certain control-related concepts. After decades in which questions of … Continue Reading

Government Shutdown Could Affect Federal Reserve Processing of M&A Applications

The partial federal government shutdown could affect the timing of processing of certain new merger and acquisition applications by the Board of Governors of the Federal Reserve System (the “Board”). Pursuant to special procedures outlined in a December 2018 notice, the Office of the Federal Register is not publishing documents during the partial government shutdown … Continue Reading

Federal Reserve Requests Public Comment on New Application Form for Savings and Loan Holding Companies

On November 30, 2018, the Federal Reserve requested comments on a new application form—the FR LL-10(e)—for savings and loan holding companies (“SLHCs”). The new form would replace Form H-(e), which was inherited from the Office of Thrift Supervision when the Dodd-Frank Wall Street Reform and Consumer Protection Act transferred supervisory authority for SHLCs to the … Continue Reading

OCC Releases Proposal to Allow Federal Savings Associations to Exercise National Bank Powers

On September 10, 2018, the Office of the Comptroller of the Currency (“OCC”) released a proposed rule to implement section 206 of the Economic Growth, Regulatory Relief, and Consumer Protection Act, codified in section 5A of the Home Owners’ Loan Act (“HOLA”).  Section 5A permits a federal savings association with total consolidated assets of $20 … Continue Reading
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