Depository Institution Management Interlocks Act: Threshold Increase for the Major Assets Prohibition in the Depository Institution Management Interlocks Act Rules

Sullivan & Cromwell LLP - December 21, 2018
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On December 20, the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation issued a notice of proposed rulemaking requesting comment on a proposal to increase to $10 billion the thresholds at which the “major assets” prohibition on management interlocks between unaffiliated depository organizations is imposed under the agencies’ regulations implementing the Depository Institution Management Interlocks Act (“DIMIA”). According to the agencies, the proposal is designed to reduce burden by decreasing the number of depository organizations subject to the prohibition and help smaller depository organizations find qualified directors. It also fulfills the commitment the agencies made in March 2017 to Congress to raise the thresholds. The proposal solicits comment on three alternative options for adjusting the thresholds, which are discussed in this memo.