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Exception Tracking Spreadsheet (TicklerTrax™)
Downloaded by more than 1,000 bankers. Free Excel spreadsheet to help you track missing and expiring documents for credit and loans, deposits, trusts, and more. Visualize your exception data in interactive charts and graphs. Provided by bank technology vendor, AccuSystems. Download TicklerTrax for free.

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OCC: Banks' response to COVID-19 governed by federal standards

OCC Bulletin 2020-62 reminds national banks, federal savings associations, and federal branches and agencies of foreign banks that, even though federal, state, and local governments have taken many actions to respond to the economic disruption caused by the spread of COVID-19, OCC-supervised institutions are governed primarily by uniform federal standards that preempt state law. The Bulletin lists types of state laws and regulations that do not apply to OCC-supervised institutions:

  • State law limitations on terms of credit, disbursements and repayments; and processing, origination, and servicing mortgages
  • State law and regulations on interest and non-interest fees
  • State actions limiting banks' ability to foreclose on defaulted loans and take possession of collateral beyond what is provided for in the CARES Act
  • Attempts to require banks to report to state and local officials

The OCC recommends that banks it supervises should consult with legal counsel to determine the applicability of any particular state or local law. Banks and their counsel may also contact the OCC with questions.

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