Letters

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Although the proposed guidance that is the subject of this story is from the OCC, it will likely affect all IBAT members regardless of charter type.  So, if you are a state bank, please read this short notice to determine if you can help.

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On July 21, 2011 IBAT commented on three rules proposed by federal banking agencies.  In separate letters, IBAT:

• Expressed belief that Credit Risk Retention rules overreach beyond Dodd-Frank requirements with respect to credit history, loan-to-value ratio, down payment and loss mitigation, and asked that these provisions be removed in final rulemaking;
• Sought to clarify conflict and confusion between EFTA and U.C.C. § 4A. on the Proposed Rule on Remittance Transfers (Regulation E); and