Skip to content
BOL Conferences
Thread Options Tools
#2210681 - 04/09/19 05:05 PM Annual Disclosure Statement - Financial
Lele Offline
Platinum Poster
Lele
Joined: Feb 2007
Posts: 827
In the Sun
Federal Register 3/18/19: FDIC has stated that it is rescinding and removing its regulation - Disclosure of Financial and Other Information. Since the regulation is being removed effective April 17, 2019, does this mean that we no longer have to have the disclosure in our lobby? Makes sense but I am still little hesitant. Plus, I am in the process of ordering new signs and do not want to pay for a sign that is not needed.
_________________________
Faith is seeing light with your heart when all your eyes see is darkness...

Return to Top
General Discussion
#2210683 - 04/09/19 05:11 PM Re: Annual Disclosure Statement - Financial Lele
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,662
See FIL-14-2019:

"Although the FDIC's final rule rescinding and removing Part 350 will not take effect until April 17, 2019, state nonmember banks and insured state-licensed branches of foreign banks need not prepare, and make available to the public, disclosure statements containing financial data for 2018 and 2017."

https://www.fdic.gov/news/news/financial/2019/fil19014.html
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

Return to Top
#2210821 - 04/10/19 09:00 PM Re: Annual Disclosure Statement - Financial Lele
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Makes sense, since the requirements of Part 350 have been outdated by technology for a while. The only reason the FDIC didn't make the regulation effective on publication is that it almost always provides 30 days lead time.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2213416 - 05/13/19 01:45 PM Re: Annual Disclosure Statement - Financial Lele
NoJustNo Offline
100 Club
Joined: Oct 2013
Posts: 221
Midwest
Just to be sure - the OCC requirement is still in place, correct? (12 CFR 18.7b)

Return to Top
#2213418 - 05/13/19 01:48 PM Re: Annual Disclosure Statement - Financial NoJustNo
NoJustNo Offline
100 Club
Joined: Oct 2013
Posts: 221
Midwest
Never mind - It appears I missed the memo that the OCC rescinded, too!

"Finally, because regulations similar to part 350 have been rescinded by the FRB and the OCC (as well as the former OTS), the preparation and availability of annual disclosure statements are no longer required by the other federal banking agencies for the institutions under their supervision."

Return to Top
#2213420 - 05/13/19 01:52 PM Re: Annual Disclosure Statement - Financial Lele
NoJustNo Offline
100 Club
Joined: Oct 2013
Posts: 221
Midwest
Does anyone know *when* the OCC requirement was rescinded?

Return to Top
#2213431 - 05/13/19 03:36 PM Re: Annual Disclosure Statement - Financial Lele
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,662
Last edited by Adam Witmer; 05/13/19 03:38 PM. Reason: Corrected the link for the right citation.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

Return to Top