Re: OCC Notice of Proposed Rulemaking, Employment Contracts, Mutual to Stock Conversions, Technical Amendments, 85 FR 1052 (Jan. 8, 2020) [RIN 1557-AE21]
Chief Counsel’s Office Attention:
Comment Processing
Office of the Comptroller of the Currency
400 7th Street SW, Suite 3E-218
Washington, DC 20219
Dear Chief Counsel:
The American Bankers Association (ABA) appreciates the opportunity to comment on the Office of the Comptroller of the Currency’s (OCC) Notice of Proposed Rulemaking. In the Proposed Rule, the OCC makes a number of simplifications and amendments recommended by comments filed in response to the Economic Growth and Regulatory Paperwork Reduction Act review. ABA supports many of the changes and appreciates the willingness of the OCC to be responsive to comments submitted. ABA also appreciates that the proposed requirements for national banks and federal savings associations have been harmonized or are the same where it makes regulatory sense to do so. ABA offers additional comments and recommendations to the proposed rule discussed.
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