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Title III: Enhancing Financial Institution Safety and Soundness

American Bankers Association Contacts

Bob Davis (202) 663-5588  (OTS and Thrifts)
Dawn Causey (202) 663-5434  (OTS and Thrifts)
Joe Pigg (202) 663-5480  (OTS and Thrifts)
Jim Chessen  (202) 663-5130  (Deposit Insurance)

Dechert LLP Authors


Thomas P. Vartanian  (202) 261-3439
Robert H. Ledig  (202) 261-3454
David L. Ansell  (202) 261-3433


The Office of Thrift Supervision ("OTS") will be eliminated under Title III. The OTS's supervisory responsibilities (not including those transferred to the Bureau) will be allocated among the three Federal bank regulatory agencies. The Fed will assume responsibility for regulating savings and loan holding companies ("SLHCs"). The OCC will assume responsibility for Federal savings associations and the FDIC will have responsibility for State savings associations. The transfer of functions is generally expected to occur 1 year from the date of enactment of the Act. The Act continues the Federal savings association charter (both in mutual and stock form) and the powers and authorities of Federal savings associations under the Home Owners' Loan Act ("HOLA") without change except with respect to Federal law preemption of state consumer protection law (see Paragraph 10.22.).

In addition to provisions dealing with HOLA and the OTS, Title III also provides for a permanent increase of FDIC deposit insurance per depositor from $100,000 to $250,000. It also modifies elements of the deposit insurance assessment program, including increasing the minimum reserve ratio for the Deposit Insurance Fund from 1.15 percent to 1.35 percent, but requires the FDIC to offset the effect of the increase on institutions with assets of less than $10 billion. The mechanics of how the FDIC handles this differentiation are left to the FDIC to develop.

The following links provide expanded analysis within this section: