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TCH Requests Extension of OCC Lending Limits Compliance Date

The Clearing House Association along with two other trade associations submitted a letter to the OCC requesting an extension of the compliance date for the lending limits rule. The letter requests a delay until the first day of the quarter that begins after the third month following the date the final rule is published (e.g., if the final rule is published before the end of June, the compliance date would be October 1). This approach takes into account the Call Report periods and should give banks enough time after the final rule is issued to plan accordingly.