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Financial Services Law Insights and Observations

OCC Releases Annual Assessment Schedule

OCC

Consumer Finance

On December 12, the OCC issued Bulletin 2013-37, which informs all national banks, federal savings associations, and federal branches and agencies of foreign banks of fees and assessments charged by the OCC for calendar year 2014. The Bulletin states that, given its increased supervisory responsibilities associated with the Dodd-Frank Act, the OCC has removed the $20 billion asset cap on inflation indexing for all asset brackets and raised the asset cap from $20 billion to $40 billion for application of the surcharge related to lower-rated institutions. Marginal rates of the OCC’s general assessment schedule continue to be indexed based on changes in the Gross Domestic Product Implicit Price Deflator for the previous June-to-June period. The 2014 adjustment will be 1.4 percent, and, given the removal of the asset cap, will apply to all assets. The Bulletin further explains that the assessment schedule continues to include a surcharge for institutions that require increased supervisory resources, and that the OCC will continue to provide a 12 percent reduction on the assessment for nonlead national banks, federal savings associations, or federal branches or agencies of a foreign bank. The new assessments are effective January 1, 2014 and are due March 31, 2014 and September 30, 2014, based on call report information as of December 31, 2013 and June 30, 2014, respectively.