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OCC Bulletin 2020-43
April 24, 2020
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Chief Executive Officers of All National Banks, Federal Savings Associations, and Federal Branches and Agencies; Department and Division Heads; All Examining Personnel; and Other Interested Parties
The federal government has taken many actions in response to the economic disruption caused by the spread of COVID-19, including establishing and implementing financial support programs. While the Office of the Comptroller of the Currency (OCC) recognizes that a wide range of stakeholders, including state and local officials, have an interest in the successful implementation of these programs, the OCC reminds banks1 that it has exclusive visitorial authority over them.
The information in this bulletin applies to all community banks.
Please contact Andra Shuster, Senior Counsel, or Priscilla Benner, Senior Attorney, Chief Counsel's Office, at (202) 649-5490.
Jonathan V. Gould
Senior Deputy Comptroller and Chief Counsel
1 The term "banks" refers collectively to national banks, federal savings associations, and federal branches and agencies of foreign banks.
2 12 USC 484, 1463(a)(1), 1464(a)(1), and 3102(b); see also, e.g., OTS Op. Chief Counsel P-2006-2, p. 5 (March 7, 2006).
3 Such exceptions are uncommon but include, for example, specific authorization for state auditors and examiners to review national bank records to ensure compliance with state unclaimed property and escheat laws upon reasonable cause to believe the bank has failed to comply with such laws. 12 USC 484(b).
4 See 12 CFR 7.4000.