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ABA: The American Bankers Association
Compliance News

ABA Staff Analysis: OCC Pilot Program Proposal

ABA issued a Staff Analysis on the OCC's proposed Innovation Pilot Program, designed to provide a framework for banks to engage with the OCC on small-scale short-term tests. Under the proposed terms of the program, OCC-supervised banks could request OCC participation in a pilot of up to 24 months. Tools that the OCC might use would include interpretive letters, supervisory feedback and technical assistance. The legal permissibility of the proposed activity must be determined before any live test can begin. Pilot projects must include reasonable controls and exit strategies. Comments on the OCC's proposed program are due by June 14.