Headlines 1. OCC to Consider Fintech Applications for Special Purpose National Bank Charters 2. Federal Banking Agencies Publish Guidance on New Credit Loss Accounting Standard 3. Federal Banking Agencies Issue Final Rule on Extended Exam Cycles 4. Division of Banks Amends Foreclosure Prevention and ATM/EFT Rules 5. Other Developments: Marijuana Guidance and Bank Fraud

1. OCC to Consider Fintech Applications for Special Purpose National Bank Charters

The Nutter Bank Report is a monthly electronic publication of the firm’s Banking and Financial Services Group and contains regulatory and legal updates with expert commentary from our banking attorneys.

The OCC has issued guidance to clarify supervisory expectations for national banks and federal savings associations in situations where secured consumer debt is discharged under Chapter 7 bankruptcy proceedings. The guidance issued on February 14 in OCC Bulletin 2014-4 describes the analysis necessary to “clearly demonstrate and document that repayment is likely to occur” to avoid the charge-off that would otherwise be required by the OCC’s Uniform Retail Credit Classification and Account Management Policy.

The good news is that public works construction projects for municipalities are projected to remain a major sector of construction activity for the foreseeable future. The not-so-good news is that municipal bankruptcy filings are on the rise, and they are likely to increase. The issues facing parties under contract with a municipality when it files for bankruptcy protection are playing out nationally in places like Stockton, California, and Detroit, Michigan.

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