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.

Additional resources:

• ABA comment letter on bank premises.
• ABA/BPI/ICBA comment letter on bank premises.