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Financial Services Law Insights and Observations

OCC Adopts Interim Final Lending Limit Rule

OCC Bank Compliance

Consumer Finance

On June 20, the OCC adopted an Interim Final Rule that applies the OCC’s existing lending limit rule to certain credit exposures arising from derivative transactions and securities financing transactions. The Dodd-Frank Act added credit exposures arising from a derivative transaction, repurchase agreement, reverse repurchase agreement, securities lending transaction, or securities borrowing transaction to the definition of loans and extensions of credit for purposes of the lending limit. The interim final rule implements the new definition, effective July 21, 2012, but gives national banks and savings association until January 1, 2013 to comply. The interim final rule permits use in certain circumstances of look-up tables for measuring the exposures for each transaction type, a change that is expected to reduce the burden on smaller institutions. The OCC is accepting comments on the interim final rule through August 6, 2012.

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