March 12, 1992
TO: BOARD OF GOVERNORS NO. 16-92
RE: INSTITUTE LETTER ON OCC REGULATORY REVIEW
__________________________________________________________
As we previously informed you, the Office of the
Comptroller of the Currency has issued a notice requesting public
comment on regulations that "may hinder economic growth". (See
Memorandum to Board of Governors No. 13-92, dated February 25,
1992.) In response, the Institute filed the attached comment
letter, which states that the OCC's proposed revisions to its
regulations governing bank common trust funds do not satisfy this
standard and should not be adopted in the course of this
regulatory review. The letter also notes that the
Administration's legislative proposal for restructuring the
financial services industry recognized that banks should not be
granted mutual fund powers in the absence of "appropriate
safeguards" designed to protect investors, depositors and the
public.
We will keep you advised of developments in this area.
Craig S. Tyle
Deputy General Counsel
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