The Federal Reserve, FDIC, and OCC have released new host state loan-to-deposit ratios to assess compliance with the Riegle-Neal Act. These ratios replace the ones from June 2022. The act prohibits banks from establishing branches outside their home state solely to acquire deposits, aiming to ensure banks also support the credit needs of local communities.
The Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency have released the host state loan-to-deposit ratios for compliance with section 109 of the Riegle-Neal Interstate Banking and Branching Efficiency Act of 1994. This section prohibits banks from establishing branches outside their home state primarily for deposit production. If a bank's statewide loan-to-deposit ratio is at least one-half of the published host state ratio, it is deemed compliant. If not, a second step is conducted to assess if the bank is adequately meeting the credit needs of the communities served by its interstate branches. Failure to comply with section 109 may result in sanctions. The ratios were estimated using available data from the Consolidated Reports of Condition and Income and Summary of Deposits Surveys as of June 30, 2022. Certain types of banks, such as wholesale or limited purpose banks under the Community Reinvestment Act, were excluded from the calculation. The host state loan-to-deposit ratios will be published annually, along with any changes in the calculation method.
The release of host state loan-to-deposit ratios by the regulatory agencies is a part of their efforts to enforce section 109 of the Riegle-Neal Interstate Banking and Branching Efficiency Act. This section aims to prevent banks from establishing branches in other states solely for the purpose of deposit production. The two-step process described in the statement indicates that compliance with section 109 is determined by comparing a bank's statewide loan-to-deposit ratio with the published host state ratio. If the bank's ratio meets the required threshold, it is considered compliant. Otherwise, the bank's contribution to meeting the credit needs of the communities it serves is evaluated. The use of proxy data from call reports and summary of deposits to estimate the ratios reflects the agencies' attempt to gather information without imposing additional regulatory burdens on institutions. Certain types of banks, such as wholesale or limited purpose banks, are excluded from the calculation due to their specific characteristics, such as large loan portfolios and limited deposits.
The FDIC
The Federal Deposit Insurance Corporation (FDIC) is an independent agency of the United States government that was established in 1933. The FDIC's primary role is to protect depositors and maintain stability in the U.S. banking system. The FDIC provides deposit insurance, which guarantees the safety of deposits in member banks up to a certain amount per depositor, currently set at $250,000 per ownership category. This insurance helps maintain public confidence in the banking system and ensures that depositors' funds are protected.
In addition to deposit insurance, the FDIC also regulates and supervises banks to ensure their safety and soundness. It examines financial institutions, monitors their compliance with banking laws and regulations, and takes appropriate action when necessary to protect depositors and the integrity of the banking system. The FDIC also plays a crucial role in the resolution of failed banks. When a bank fails, the FDIC may step in as the receiver and oversee the orderly liquidation or sale of the bank's assets, ensuring that insured depositors are promptly reimbursed.
Overall, the FDIC serves as a vital institution in maintaining the stability, integrity, and public confidence in the U.S. banking system through deposit insurance, bank supervision, and resolution of failed banks.
The OCC
The Office of the Comptroller of the Currency (OCC) is an independent bureau within the U.S. Department of the Treasury. Its primary mission is to ensure the safety and soundness of the national banking system and to protect the rights of bank customers. The OCC is responsible for chartering, regulating, and supervising all national banks and federal savings associations in the United States. It oversees approximately 1,200 national banks and federal savings associations, which together represent a significant portion of the U.S. banking system.
The OCC's main functions include:
- Chartering: The OCC has the authority to grant national bank charters to new banks and federal savings association charters to savings institutions. It evaluates the applications and ensures that the institutions meet the necessary requirements.
- Supervision and Examination: The OCC conducts regular examinations of national banks and federal savings associations to assess their safety and soundness, compliance with laws and regulations, and overall risk management practices. It provides guidance and supervision to address any issues or deficiencies identified during these examinations.
- Regulation and Policy: The OCC establishes and enforces regulations and policies that govern the operations of national banks and federal savings associations. It issues guidelines, interpretations, and bulletins to provide clarity and guidance to the institutions it supervises.
- Consumer Protection: The OCC works to protect consumers by ensuring fair treatment and adherence to consumer protection laws and regulations. It provides oversight and enforcement related to consumer financial laws, including the Community Reinvestment Act, which promotes lending and investment in low- and moderate-income communities.
- Community Reinvestment Act (CRA): The OCC is responsible for assessing and evaluating the CRA performance of national banks and federal savings associations. It encourages these institutions to meet the credit needs of their communities, particularly in underserved areas.
- Enforcement and Compliance: The OCC has the authority to take enforcement actions against banks and individuals for violations of banking laws and regulations. It can impose penalties, issue cease and desist orders, and remove officers and directors when necessary.
Overall, the OCC plays a crucial role in ensuring the safety, soundness, and fairness of the national banking system, as well as promoting consumer protection and community development through its regulatory, supervisory, and enforcement functions.
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