FDIC, FRB, OCC, OTS: EGRPRA Reg Burden Review – Part 4: Money Laundering, Safety and Soundness, and Securities Regulations 2005

ABA Contact: Paul Smith, (202) 663-5331
Published: 70 Federal Register 5571; February 3, 2005
Comments Due: May 4, 2005
Disposition: Filed


This is the fourth round in the Agencies' EGRPRA review. Section 2222 of the Economic Growth and Regulatory Paperwork Reduction Act of 1996 (EGRPRA) requires federal agencies to review their regulations at least once every 10 years. See Interagency Announcement. See also the ABA's pages on EGRPRA. This comment period requests comments on the following regulations (ABA staff contact and email is listed by each regulation):

Money Laundering, Safety & Soundness, and Securities Regulations

1. Money Laundering
A. Bank Secrecy Act Compliance John Byrne
B. Reports of Crimes or Suspected Crimes John Byrne
2. Safety and Soundness
A. Appraisal Standards John Byrne
B. Frequency of Safety and Soundness Examination Paul Smith
C. Lending Limits Paul Smith
D. Real Estate Lending Standards Paul Smith
E. Security Devices & Procedures John Byrne
F. Standards for Safety & Soundness Paul Smith
G. Transactions with Affiliates Paul Smith
H. OCC OREO (Other RE Owned) Paul Smith
I. FRB Reg A (credit from Federal Reserve Banks) Paul Smith
J. FRB Limits on Interbank Liabilities Paul Smith
K. FDIC Annual Independent Audits & Reporting Requirements Donna Fisher
Jim McLaughlin
L. FDIC Unsafe & Unsound Banking Practices (Standby Letters of Credit Brokered Deposits) Paul Smith
M. OTS Audits of Savings Associations & Holding Companies John Rasmus
Donna Fisher
N. OTS Financial Management Policies John Rasmus
O. OTS Additional Limits on Lending & Investment John Rasmus
3. Securities
A. Banks as Registered Clearing Agencies Sarah Miller
B. Banks as Securities Transfer Agents Sarah Miller
C. Government Securities Sales Practices Sarah Miller
D. Recordkeeping and Confirmation of Securities Transactions by Banks Sarah Miller
E. Reporting Requirements for Reported Securities Under the Exchange Act of 1934 Sarah Miller
F. OCC and OTS Securities Offerings Sarah Miller
G. OCC Municipal Securities Dealers Activities of National Banks Cris Naser
H. FRB Regulation U (Credit for Margin Stock) Sarah Miller
I. OTS Accounting Requirements/Financial Statements Donna Fisher
J. OTS Proxies Sarah Miller
K. OTS Rules on Issuance and Sale of Institution Securities Sarah Miller

Issues to consider for comment include whether a statutory change is needed to reduce the burden, whether the regulations are consistent with their statute of authority, what are the most burdensome reporting requirements and are any of them unnecessary, and how might the burden be lessened on small institutions.

Comments may be submitted electronically at the Agencies' EGRPRA website. Please copy any comments to Paul Smith.

2005 Regulations Chart
Federal Register
Comment Letter