Swaps Pushout Rule: OCC Prepared to Grant Two-Year Transition Period to Federal Insured Depository Institutions
The OCC has published long-awaited guidance notifying federally-chartered insured depository institutions (“IDIs”) that it is prepared to grant applications to delay compliance with the Swaps Pushout Rule for up to 2 years. Such IDIs must submit a formal request to the OCC by January 31, 2013. We believe that the Federal Reserve and the FDIC will issue similar guidance to state-chartered IDIs subject to their primary supervision. But it remains to be seen whether such guidance will address the application of the Swaps Pushout Rule to uninsured U.S. branches and agencies of foreign banks. In addition to the OCC’s guidance, this memorandum discusses the Swaps Pushout Rule’s controversies, implications and uncertainties.
This communication, which we believe may be of interest to our clients and friends of the firm, is for general information only. It is not a full analysis of the matters presented and should not be relied upon as legal advice. This may be considered attorney advertising in some jurisdictions. Please refer to the firm's privacy notice for further details.
Copy link to share post