Large Bank Supervision Forum 2023

Current State: Key advantages of the state Charter

• Accessibility to decision makers promotes faster resolution of issues • Knowledge of local and regional economic conditions • State regulatory staff is more consistent • State supervisory approach is steadier over time – Less political uncertainty • Coordination with federal regulators • Lower costs

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Confidential (For State Bank Supervisors Only) / Not For Redistribution / Pre ‐ Decisional

Current State Pain Points:

• Conducting business in states without a branch or online • For State Banks there are inconsistent definitions and requirements for: • Determining what constitutes banking in a state.

• Establishing non-branch offices - Loan Production and Deposit Production offices • Exempting banks and bank subsidiaries from nonbank licensing requirements • Is there Parity between requirements for state and national banks? •Bank name restrictions or common names need to be resolved state by state • National Banks operate with a single set of standards • OCC NPR on activities and operations of National banks will create further inequality between state and national banks – June 2020

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Confidential (For State Bank Supervisors Only) / Not For Redistribution / Pre ‐ Decisional

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