Implementation of Regulatory Relief Provisions of S 2155

The formal process to amend affected regulations to reflect the statutory changes of the Economic Growth, Regulatory Reform, and Consumer Protection Act will take some time. In the interim, OCC Comptroller Otting has directed agency staff to consider those relief provisions of the law that were legally effective with the law’s enactment, as being immediately effective even though formal rule-writing has not been completed. Comptroller Otting is advising OCC-supervised institutions to directly contact their regional OCC office to confirm that a particular provision of the law is immediately effective prior to making operational decisions to change processes and procedures.

While the FDIC and FRB have not expressed their position regarding implementation, it can be logically assumed that the three prudential regulators will operate in tandem with respect to timely implementation of the relief provisions contained in the law. Bankers should ensure close coordination with their primary regulators during the implementation period. 

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