Large Bank Supervision Forum 2023

Current State Pain Points:

• Interstate trust operations • For State Banks and trust companies there are inconsistent definitions and requirements for:

• Acting as a fiduciary or engaging in trust business in a host state • Conducting remote trust activities outside of the home state • Operating trust representative offices or full-service trust offices

• Reciprocity requirements differ state to state • Host state supervisory or enforcement authority over an out-of-state trust institution varies state by state • Examinations are not coordinated among states that have supervisory authority • Capital requirements, Call Report confidentiality, and exam frequency vary by state. • National Banks and trust companies operate with a single set of standards

7

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

Other Key findings

• Confidential supervisory information sharing • Banks are put in the middle of information sharing requests between states • FBO's, Intermediate Holding Companies, Foreign Regulators, Fed, and FDIC • Examinations of nonbank subsidiaries and affiliates are not coordinated among the states when licenses are required. • Mortgage and consumer finance affiliates are examined by multiple states without involvement from the home state. • Certain laws vary by state – applicability of state law is unclear • Consumer loan terms and disclosures differ state to state • California privacy provisions • New York cyber rules • Local COVID 19 protections on forbearance and eviction relief

8

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