Not an attorney, but I saw this
“Bank Regulated Institutions†means all banks, trust companies, private bankers, savings banks, and savings and loan associations chartered pursuant to the New York Banking Law (the “Banking Lawâ€) and all branches and agencies of foreign banking corporations licensed pursuant to the Banking Law to conduct banking operations in New York.
As far as I can tell, that would not include an OCC regulated Bank. I think you're right though. It will all come down to how the final rule is written.
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu