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March 29, 2002
Office of the Comptroller of the Currency
Public Information Room
250 E Street, S.W. Mail stop 1-5
Washington, D.C. 20219
Attention: Docket No. 02-02
Re: International Banking Activities: Capital Equivalency
Deposits
Dear Sir or Madam:
The Conference of State Bank Supervisors (CSBS) is pleased to have
the opportunity to comment on the Office of the Comptroller of the
Currency (OCC) interim rule amending its regulation regarding the
capital equivalency deposits (CED) for federal branches or agencies
of foreign banks[1].
As you know, CSBS is the national organization of state officials
responsible for chartering, regulating and supervising the nation?s
6,000 state-chartered banks and 530 state-licensed foreign banking
organizations.
We direct our comments to your solicitation of comments on ?how to
make this rule clearer.? To some readers, the language of the rule
has raised a question of whether the rule intends or attempts to
reduce the statutory minimum CED provided in 12 U.S.C. 3102(g)(2),
specifically the requirement that foreign institutions must maintain
a CED equal to 5 percent of liabilities. We note that the OCC
recently reiterated this principle. In the March 4, 2002 news
release (NR 2002-16) announcing regulatory burden reduction for
well-managed federal branches, the Comptroller stated unequivocally
that the changes did not affect the statutory minimum, and that the
?five-percent requirement remains in effect.? We commend the clarity
of the news release, and respectfully suggest the rule likewise be
clarified to state specifically that the rule does not reduce the 5
percent minimum requirement nor is it intended to do so.
Thank you for this opportunity to comment. If you have any
questions, please contact me at 202-296-2840.
Sincerely,
Timothy N. Bergan
Senior Vice President
International
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[1]
67 Fed. Reg. 4325, (January 30, 2002) |
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