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Date Published
Comment Letter

Fiduciary Capacity; Non-Fiduciary Capacity Custody Activities

Jun 29, 2019
In this letter, CSBS raises concerns regarding the impetus for and permissibility of these contemplated proposals and reiterates concerns regarding the validity of the OCC’s multistate fiduciary operations rules.
Policy

Letter on Pending ILC Legislation

Nov 15, 2021
The Honorable Jesus “Chuy” Garcia U.S. House of Representatives Washington, D.C. 20515 Dear Representative Garcia: On behalf of the Conference of State Bank Supervisors (CSBS), 1 I write to express our concern regarding legislation Congress is considering eliminating the exemption for industrial loan companies (“ILCs”) from the definition of a bank under the Bank Holding Company Act (“BHCA”). State regulators
Tags
Industrial Loan Companies (ILCs)
Page

CSBS 2023 Data Analytics Competition

2023 Challenge: What will be the potential impact on banks from the recent rapidly rising interest rate environment?
Job Aids

MMC Cares Act Compliance Exam - Procedures (General)

Aug 12, 2021
Job Aids

MMC Cares Act Compliance Exam - Loan File Review Worksheet

Aug 12, 2021
Job Aids

MMC Cares Act Compliance Exam - Information Request

Aug 12, 2021
Policy

FDIC Board Seat Letter to Senate Leadership

Jan 31, 2022
In 1996, with overwhelming support, Congress amended the Federal Deposit Insurance Act to require that one of the positions on the FDIC Board be held by someone with “State bank supervisory experience.”
Tags
FDIC State Representation on the FDIC Board
Policy

FDIC Board Seat Letter to the White House

Jan 31, 2022
The letter and the spirit of the law all indicate that this FDIC Board Seat requirement is only met by a person who has worked in state government as a supervisor of state-chartered banks
Tags
FDIC State Representation on the FDIC Board
Comment Letter

Community Reinvestment Act Changes

Aug 5, 2022
Benjamin W. McDonough, Chief Counsel Chief Counsel’s Office Attention: Comment Processing Office of the Comptroller of the Currency 400 7th Street SW, Suite 3E-218 Washington, DC 20219 Docket ID OCC-2022-0002 Ann E. Misback, Secretary Board of Governors of the Federal Reserve System 20th Street and Constitution Avenue NW Washington, DC 20551 Docket No. R-1769 RIN 7100-AG29 James P. Sheesley, Assistant
Comment Letter

FinCEN No-Action Letter Process

Aug 5, 2022
Financial Crimes Enforcement Network Enforcement and Compliance Division P.O. Box 39 Vienna, VA 22183 FINCEN-2022-0007 RIN 1506-AB55 Re: Advance Notice of Proposed Rulemaking – No-Action Letter Process Dear Sir or Madam, The Conference of State Bank Supervisors (“CSBS”)1 appreciates the opportunity to provide input on the Advance Notice of Proposed Rulemaking (“ANPR”) issued by the Financial Crimes Enforcement Network (“FinCEN”)