Dodd-Frank and agency consolidation

Although the specific requirements and burdens of the almost 250 regulations and more than 2000 pages in the Dodd-Frank Act are yet to be clearly defined, one of the major provisions of immediate interest to financial institutions is the elimination of the Office of Thrift Supervision (OTS).  The OTS operations will be merged into the Office of the Comptroller of the Currency (OCC), which will have an immediate impact on thrift chartered banks as they adapt to the safety and soundness compliance requirements of the OCC.  Details are that the OTS regulatory responsibilities will be spread among other regulators. The Federal Reserve will regulate savings and loan holding companies, the OCC will regulate federal savings associations, and the FDIC will regulate State savings associations.

I believe that this consolidation, in combination with the memorandum signed between the FDIC and the other primary federal regulators, will lead to increased safety and soundness scrutiny across the board.  All financial institutions, particularly those regulated by the OTS, are strongly encouraged to monitor regulatory activity closely over the next several months and take a proactive approach to pre-empt surprises during regulatory safety and soundness and  examinations.

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