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To: Chief Executive Officers of All National Banks, Federal Savings Associations, and Federal Branches and Agencies of Foreign Banks; Department and Division Heads; All Examining Personnel; and Other Interested Parties

Description: Notice of Proposed Rulemaking


The Office of the Comptroller of the Currency (OCC) published a notice of proposed rulemaking in the Federal Register on January 31, 2019, that would increase the major assets prohibition thresholds for management interlocks in the OCC’s rule implementing the Depository Institution Management Interlocks Act (DIMIA). The proposed rule was issued jointly with the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation (together with the OCC, the agencies).

The agencies will accept comments on this notice of proposed rulemaking through April 1, 2019.

Note for Community Banks

The proposed rule would reduce the number of national banks and federal savings associations subject to the major assets prohibition in the OCC’s DIMIA rule by increasing both major assets prohibition thresholds from $1.5 billion and $2.5 billion to $10 billion.


The DIMIA major assets prohibition precludes a management official of a depository organization with total assets exceeding $2.5 billion (or any affiliate of such an organization) from serving at the same time as a management official of an unaffiliated depository organization with total assets exceeding $1.5 billion (or any affiliate of such an organization). DIMIA provides that the agencies may adjust, by regulation, the major assets prohibition thresholds to allow for inflation or market changes. To account for changes in the U.S. banking market since the current thresholds were established in 1996, the agencies are proposing to raise both thresholds to $10 billion. In addition, the agencies are proposing three alternative approaches for increasing the thresholds based on market changes or inflation.

Further Information

Please contact Daniel Perez, Attorney, or Christopher Rafferty, Attorney, Chief Counsel’s Office, at (202) 649-5490.


Jonathan Gould
Senior Deputy Comptroller and Chief Counsel

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