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6.23 New Penalties for Violating the Qualified Thrift Lender Test

<< Title VI Overview

6.23 New Penalties for Violating the Qualified Thrift Lender Test

 

 


6.23.     New Penalties for Violating the Qualified Thrift Lender Test.  If a savings association fails to become and remain a qualified thrift lender ("QTL"), it is immediately subject to certain restrictions and possible enforcement action.  This is in contrast to the current HOLA provisions that require QTL failing savings associations to either become banks or become subject to certain restrictions.  The Act provides that if a savings association fails the QTL requirement, the savings institution would be limited to paying only those dividends that would be permissible for a national bank, that are necessary to meet the obligations of any company that controls the savings association, and that are specifically approved by the OCC and the Fed. [§ 624]