The Bank Policy Institute (BPI), the American Bankers Association (ABA), and the Independent Community Bankers of America (ICBA) recently forwarded correspondence to the Office of the Comptroller of the Currency (OCC), urging the agency to withdraw its proposed change in position regarding bank premises.
The three organizations stand in opposition to the OCC’s Notice of Proposed Rulemaking on National Bank and Federal Savings Association Premises.
The organizations maintain that the OCC’s plan would abandon a principles-based approach to regulating what banks can do with their sites, land, and facilities that has worked well for decades, replacing the policy by adopting a bright-line, rules-based approach.
“In any case, as they consider changes to space needs and use, banks need flexibility to adapt to an uncertain future,” the organizations wrote. “Implementing the Proposal now would interfere with banks’ ability to adapt to changing premises needs and arrangements in a post-pandemic working environment, detracting from their ability to hire competitively.”
Additionally, the groups have determined the proposal’s lack of flexibility would diminish the ability of banks to adapt to the post-pandemic transformation of work and business environments, in addition to other future changing circumstances.
“In the absence of any demonstration that the current approach has been defective and in light of the challenges of the pandemic and the uncertainties presented by expected changes to the post-pandemic work and business environments, we strongly recommend that the OCC withdraw the Proposal,” the organization’s concluded. “If in the future the OCC determines that changes to its premises regulations should be implemented, the OCC
should propose changes after there has been an opportunity to evaluate the impact of a post-pandemic working environment on banks’ premises needs.”
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