OCC Finalizes Fair Access Rule

On 1/14/21, the OCC issued a final rule to ensure fair access to banking services provided by large national banks, federal savings associations, and federal branches and agencies of foreign bank organizations. In their release, the OCC explains that the rule codifies more than a decade of OCC guidance stating that banks should conduct risk assessment of individual customers, rather than make broad-based decisions affecting whole categories or classes of customers, when provisioning access to services, capital, and credit. The rule implements language included in Title III of the Dodd–Frank Wall Street Reform and Consumer Protection Act of 2010, which charged the OCC with "assuring the safety and soundness of, and compliance with laws and regulations, fair access to financial services, and fair treatment of customers by, the institutions and other persons subject to its jurisdiction."

According to the OCC release, the rule applies to the largest banks with more than $100 billion in assets that may exert significant pricing power or influence over sectors of the national economy. Under the rule, banks still determine their product lines and geographic markets and are free to make legitimate business decisions about what and whom to serve. The rule requires covered banks to make those products and services they choose to offer available to all customers in the communities they serve, based on consideration of quantitative, impartial, risk-based standards established by the bank. Under the rule, a covered bank's decision to deny services based on such objective assessment would not violate the bank's obligation to provide fair access. However, a covered bank's decision not to offer a specific kind of financial product or service or not to compete in a geographic market is unaffected.

The full rule can be found here.

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