By Gina Ellis, CRCM
On December 15, 2016, the Office of the Comptroller of the Currency (OCC) issued News Release 2016-156 removing outdated or unnecessary provisions of certain rules. Among those is the financial disclosure requirement found in 12 CFR Part 18. Specifically, Part 18 requires national banks to prepare financial disclosure statements which include information from a bank’s Call Report as of December 31 of each year. Banks were also required to post a notice in the lobby of the main office and each branch location that the financial disclosure was available, indicating the name and telephone number of the person or office to contact for a copy of the financial information.
The OCC determined the information required by Part 18 is disclosed in other publicly available documents, such as the Call Report and the Uniform Bank Performance Report (UBPR). Therefore, to eliminate duplicative information, Part 18 was completely eliminated.
What does that mean for you? Effective April 1, 2017, if your primary federal regulator is the OCC, you no longer need to post notice of availability of financial information in your lobby areas or have financial information available if requested. The former Office of Thrift Supervision (OTS) and the Federal Reserve Board rescinded similar regulations for savings associations and state member banks in 1995 and 1998, respectively.
You can find the OCC’s rescission of its requirement published in the Federal Register, January 23, 2017, page 8097: https://www.occ.gov/news-issuances/news-releases/2016/nr-occ-2016-156a.pdf
However, banks regulated by the Federal Deposit Insurance Corporation (FDIC) will still need to comply with 12 CFR 350 by providing access to annual financial information and continuing to post lobby notices at the main office and each branch location indicating the contact person or office to obtain the financial information.
You can find the FDIC’s requirement to disclose financial information in 12 CFR 350 here:
https://www.fdic.gov/regulations/laws/rules/2000-7300.html
As always, we are here to help! Stay connected with us at www.americanbanksystems.com or call us at (405) 607-7000.
