Lending Limits

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The Office of the Comptroller of the Currency (OCC) is proposing to comprehensively revise its rules governing national bank lending limits. This proposal is the first in a series of proposals intended to simplify OCC regulations and reduce compliance costs. The proposed revisions clarify the scope and application of the lending limits; reorganize the regulation to group related subjects together; update the rules to address frequently asked questions and incorporate significant OCC interpretations of the lending limits; simplify calculation of the lending limits by relying primarily on quarterly Call Report information, rather than requiring that lending limits be calculated on a daily basis; revise the definition of capital and surplus upon which lending limits are based to rely on capital components that a bank must already calculate for Call Report purposes; add and amend definitions and consolidate definitions at the beginning of the regulation; restructure and clarify the loan combination rules; and add a new exception to the lending limits to allow a bank to advance funds to renew and complete funding a loan commitment under circumstances where the additional advance will pr