Question:
With regard to the FDIC’s Part 350 Annual Disclosure Statement rescission, would it only apply to one of our charters or would it apply to the holding company and everything under it as a whole? We are two chartered banks under one holding company.
Answer:
The rescission applies to all FDIC supervised bank at the federal level, so in your case, it appears that it would apply to both banks independently, regardless of whether they’re both under a holding company:
…This Financial Institution Letter applies to all FDIC-supervised institutions, including community institutions….
FDIC: FIL-14-2019: Removal of the FDIC’S Part 350 Annual Disclosure Statement Requirement
Removal of the FDIC’s Part 350 Annual Disclosure Statement Requirement Printable Format: FIL-14-2019 – PDF (). Summary: On March 8, 2019, the FDIC Board approved a final rule rescinding and removing Part 350 of the FDIC’s regulations, which is entitled Disclosure of Financial and Other Information by FDIC Insured State Nonmember Banks. The FDIC is taking this action to simplify its regulations …
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