Alert November 15, 2011

Federal Savings Associations to be Subject to Standard OCC Appeals Process

Pursuant to Section 316 of the Dodd-Frank Act, the OCC issued a bulletin (the “Bulletin”), revising its procedures for national banks to appeal OCC actions and decisions to include federal savings associations.  The Bulletin  provides for a uniform appeals process for national banks, federal savings associations, and federal branches and agencies.  The Bulletin replaces the prior OCC appeals guidance relating to national banks and repeals the existing OTS appeals guidance.