Non-U.S. banks establishing direct banking offices in the United States, such as branches or agencies, have the option to be licensed by a state banking regulator, such as the New York State Department of Financial Services, or the U.S. Department of the Treasury, Office of the Comptroller of the Currency (OCC). The OCC recently issued a paper providing an overview of its approach to regulating federal branches and agencies of non-U.S. banks (OCC Paper).1
This month’s column will discuss this recent paper and another OCC issuance regarding its revised process for managing supervisory issues of concern arising out of examinations, including those of federal branches and agencies of non-U.S. banks.2 For those non-U.S. banks with direct banking offices in the United States, this information will be familiar. For those non-U.S. banks considering establishing a direct banking office in the United States, this information should be taken into account as you decide whether and how to engage in banking operations in the United States.
In the Beginning…
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