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Subject: Short-Term Investment Funds Reporting Requirements
Date: March 5, 2013
To: Chief Executive Officers and Compliance Officers at All National Banks, Federal Branches of Foreign Banks, and Federal Savings Associations; Department and Division Heads; All Examining Personnel; and Other Interested Parties
Description: Monthly Disclosures
The Office of the Comptroller of the Currency (OCC) published a final rule in the Federal Register on October 9, 2012, that revised the requirements imposed on national banks and federal branches of foreign banks (collectively, banks) that offer short-term collective investment funds (STIF).1 The final rule also requires federal savings associations (FSA), by operation of 12 CFR 150.260, to comply with the national bank collective investment fund (CIF) regulation (12 CFR 9.18), including the STIF provisions, if an FSA establishes and administers a CIF. 2
In the preamble to the final STIF rule, the OCC pledged to provide guidance to banks that describes the process for making electronic disclosures to the OCC. This bulletin transmits that guidance, which the OCC promised to provide at least 90 days before the rule becomes effective on July 1, 2013.
The final rule requires that a bank managing a STIF disclose information about the fund and its portfolio holdings to the OCC within five business days after the end of each month.3 To facilitate this reporting requirement, the OCC has established a secure file transfer protocol (FTP) Web site and created a standardized data collection template. Banks and FSAs that offer STIFs must request access to the FTP site and are encouraged to visit the OCC’s Asset Management STIF Web site (http://www.occ.gov/topics/capital-markets/asset-management/short-term-investment-funds.html) for registration information. The site also contains the data collection template and line-by-line template instructions.
Banks and FSAs are required to comply with the STIF final rule, including the monthly STIF disclosure requirement, beginning July 1, 2013. The first monthly disclosures are due to the OCC by August 7, 2013.
For More Information
For questions regarding the monthly STIF disclosure requirements, please contact David Barfield, National Bank Examiner, Market Risk Division, at (202) 649-6396; or Joel Miller, Group Leader, Asset Management, at (202) 649-6417.
John C. Lyons Jr.