The first of three compliance deadlines for US regulations requiring resolution-related amendments to qualified financial contracts is January 1, 2019, and delaying compliance until the subsequent deadlines creates additional risk. Compliance programs may not be able to eliminate this risk due to the scope of contracts to be remediated and the staggered compliance period that looks back to the first compliance date.
Introduction
On Friday, the Office of the Comptroller of the Currency closed Community National Bank at Bartow [http://www.occ.treas.gov/ftp/release/2010-101.htm], headquartered in Bartow, Florida, and Independent National Bank, headquartered in Ocala, Florida, and appointed the FDIC as receiver.
On Friday, the Office of the Comptroller of the Currency closed Home National Bank, headquartered in Blackwell, Oklahoma, and the FDIC was appointed receiver.
On Friday, the Office of the Comptroller of the Currency closed First National Bank, headquartered in Rosedale, Mississippi, and appointed the FDIC as receiver.
Yesterday, the Office of the Comptroller of the Currency closed BC National Banks, headquartered in Butler, Missouri, and appointed the FDIC receiver.
Friday, the Office of the Comptroller of the Currency closed Amcore Bank, National Association, headquartered in Rockford, Illinois, and the FDIC was appointed receiver.