FDIC proposed to rescind and remove from the Code of Federal Regulations 12 CFR part 390, subpart R, entitled Regulatory Reporting Standards (part 390, subpart R). The part 390, subpart R addresses regulatory reporting requirements, regulatory reports, and audits. After reviewing the requirements in part 390, subpart R, FDIC proposes to rescind part 390, subpart R in its entirety. Rescinding part 390, subpart R will serve to streamline the FDIC rules and eliminate redundant, duplicate, or otherwise unnecessary regulations in light of other FDIC regulations that govern these matters and apply to insured depository institutions, including state savings associations. Comments must be received by November 01, 2019.
The policy objectives of the proposed rule are two-fold. The first is to simplify the FDIC regulations by removing unnecessary ones and thereby improving the ease of reference and public understanding. The second is to promote parity between the state savings associations and the state nonmember banks by having the regulatory reporting requirements, regulatory reports, and audits of both classes of institutions addressed in the same FDIC rules. Certain Office of Thrift Supervision (OTS) regulations transferred to FDIC by the Dodd-Frank Act relating to regulatory reporting requirements, regulatory reports, and audits of state savings associations have been found redundant or unnecessary in light of applicable statutes and other FDIC regulations. This proposal would eliminate those transferred OTS regulations.
As of June 30, 2019, FDIC supervises 3,424 depository institutions, of which 38 (1.1%) are state savings associations. The proposed rule would affect regulations that govern state savings associations. The proposed rule would remove sections 390.320, 390.321, and 390.332 of part 390, subpart R because these sections are redundant of, or otherwise unnecessary in light of, applicable statutes and other FDIC regulations regarding audits, reporting, and safety and soundness. Rescinding and removing these regulations will not have any substantive effects on the state savings associations or the FDIC-supervised institutions.
Related Link: Federal Register Notice
Comment Due Date: November 01, 2019
Keywords: Americas, US, Banking, Reporting, State Savings Association, Dodd-Frank Act, FDIC
Scott is a Director in the Regulatory and Accounting Solutions team responsible for providing accounting expertise across solutions, products, and services offered by Moody’s Analytics in the US. He has over 15 years of experience leading auditing, consulting and accounting policy initiatives for financial institutions.
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