ARTICLE
7 February 2019

OCC Revises "Subsidiaries And Equity Investments" Booklet

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Cadwalader, Wickersham & Taft LLP

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The Office of the Comptroller of the Currency ("OCC") revised the "Subsidiaries and Equity Investments" booklet of the Comptroller's Licensing Manual.
United States Finance and Banking

The Office of the Comptroller of the Currency ("OCC") revised the "Subsidiaries and Equity Investments" booklet of the Comptroller's Licensing Manual. The updated version describes the activities of federal savings associations that "may be performed in operating subsidiaries and service corporations, or through pass-through investments."

The revised booklet:

  • outlines the types of subsidiaries and other business entities that banks may "establish or acquire and the activities in which such entities may engage";
  • specifies permissible equity investments;
  • outlines "permissible and incidental activity";
  • defines "statutory and regulatory factors" that the OCC takes into account when reviewing applications;
  • provides guidance on requirements for "insurance, electronic and fiduciary activities."

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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