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Financial Services Law Insights and Observations

OCC Extends Compliance Date for Lending Limits Rule

OCC

Consumer Finance

On November 14, the OCC issued Bulletin 2012-36 to extend until April 1, 2013 the deadline for covered institutions to comply with the OCC’s lending limit rule. In June 2012 the OCC implemented a Dodd-Frank Act requirement that the OCC’s existing lending limit rule apply to certain credit exposures arising from derivative transactions and securities financing transactions, and originally allowed national banks and savings association until January 1, 2013 to comply.