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February 28, 2014

Enhancing Transparency in the Federal Reserve’s Applications Process

The Board stated that the report will include statistics on the length of time taken to process various applications and notices and the overall volume of approvals, denials, and withdrawals. The report also will provide the primary reasons for withdrawals. The first report will be released in the second half of 2014 and will include filings acted on from January through June 2014. The letter also describes common issues identified by the Federal Reserve that have led to recent withdrawal of applications, including:

  • Less-than-satisfactory supervisory rating(s) for safety and soundness;
  • Less-than-satisfactory supervisory rating(s) for consumer compliance, or CRA;
  • Inadequate compliance with the Bank Secrecy Act ;
  • Concerns regarding the financial condition (capital, source of strength & acquisition debt);
  • Management of the proposed organization;
  • Adverse Comments; and
  • Competitive and Financial Stability Factors.
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Subchapter S Bank Association

112 East Pecan St., Suite 2810
San Antonio, TX 78205
Phone: 210-228-9500
Fax: 210-228-0781

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