Mar 24, 2021
On the latest episode of the ABA Banking Journal Podcast, ABA
Senior Counsel Shaun Kern discusses the OCC’s recent proposal to
revise its rules on permissible bank premises for national banks
and federal thrifts, as well as ABA’s
call for the agency to withdraw the proposal. During the
conversation, Kern discusses:
- How the proposed approach might arbitrarily limit banks’
ability to plan for their present and future space needs.
- How the proposal could make it harder for banks to reorganize
their spaces to accommodate employees and customers safely to
address concerns over COVID-19 amid a rapidly changing commercial
real estate landscape.
- The proposal’s lack of provision for bank customers in its
calculation of space use.
- Why the proposal’s grandfathering provision would likely not
provide the desired relief.