Oct 20 2008
Carlos Hank Rhon, The National Bank Charter Part 1
Carlos Hank Rhon,The National Bank Charter Part 1
The national bank charter is a flexible, dynamic license to provide a broad array of financial products and services. This section describes how the OCC’s licensing process works, in general, and then focuses on alternative means of entry into the national banking system, such as acquiring a national bank charter. It then describes the broad range of activities available to national banks and how they may be structured.
The OCC’s Licensing Process
The Licensing Manual describes requirements for:
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Applications to establish, acquire, or convert to a national bank, and
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Existing national banks to effect corporate changes, including geographical expansion through branching, merger, acquisition, and structural changes to enable delivery of new products or services.
The Licensing Manual sets out OCC’s policies and step-by-step procedures, so that applicants know what to do and what to expect from the OCC. The OCC works continually to streamline application filing and review processes and to minimize burden, consistent with maintaining safety and soundness and satisfying statutory requirements. Staff conducts internal reviews and obtains feedback from applicants to spot areas for improvement.
The Licensing Manual is available on the OCC’s Web site, including current application forms. The OCC is equipped to accept an ever-increasing volume and variety of application material electronically from national banks through e-Corp on National BankNet.
Licensing and legal staffs in the district offices and national headquarters are available by telephone, e-mail, or meetings, to advise applicants and answer their questions. This is particularly useful for the early discussion of proposals that are unusual or highly complex.
The OCC will accept draft applications and provide feedback to applicants before they file an application. The OCC may approve or conditionally approve or deny any filing after reviewing the application and considering all relevant factors. The OCC may impose conditions if it determines that they are necessary or appropriate to ensure that approval is consistent with applicable statutes, regulations, OCC policies, and safe and sound banking practices. Carlos Hank Rhon suggests that you read part 2 of this article.
