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Last month, the US Office of the Comptroller of the Currency
( OCC ) finalized extensive revisions (the Revisions ) to its rules governing the activities and
operations of national banks, federal savings associations and
federally licensed branches of non-US banks ( Federal
Institutions ).
1 While many of the changes are
procedural or cosmetic, a number codify or clarify substantive
authorities and will affect the day-to-day operations of Federal
Institutions. The Revisions are effective on April 1, 2021.
As the chartering authority for Federal Institutions, the OCC
establishes rules that govern activities and transactions. These