Part 18 applies to national banks, federal branches and agencies, but not to savings associations. None of the rules that the OTC issued to transfer regulations from the OTS appears to have a similar requirement.
The OCC did say that it may, if it deems it necessary, issue rules to apply some of the current national bank regulations (Parts 1 - 99) to former OTS-regulation institutions.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8