Regulatory Bulletin Regulatory Bulletin Update 2
The Division of Banks (DOB) Issues its second round of results from its Regulatory Review Initiative
One of the key objectives for the DOB is to complete a comprehensive review of all bank and credit union Regulatory Bulletins and regulations to determine opportunities for the agency to reduce regulatory burden and compliance redundancy by streamlining, updating, or repealing requirements wherever possible. This initiative was a result of the several industry focus groups that the DOB held throughout the Commonwealth of Massachusetts during 2011, and is a component of the DOB’s current strategic planning process. The DOB believes it is helpful to issue periodic updates of the changes being made to date. Below are brief descriptions of such changes made in this second round, as listed under each major category of the Regulatory Bulletin Manual. As further progress is made, additional updates will be provided.
Banks, credit unions, and licensees - consumer protection
- 1.3-103 Consumer protection and Fair Lending examinations
- Minor revisions were made to this bulletin to clarify the DOB's authority to enforce state and federal regulations.
Banks and credit unions - risk management
- 2.2-102 Management information systems examinations
- This bulletin has been repealed in its entirety. However, the language relative to the need for information technology providers to provide a Letter of Assurance acknowledging that their services will be subject to regulation and examination by the DOB to the same extent as if the services were being performed by the entity itself on its own premises has been updated and incorporated into Regulatory Bulletin 1.1, which currently remains under review.
- 2.2-103 Exclusive leases and other restrictive agreements
- This bulletin was updated to broaden the exemptions from its restrictions, to update the Board of Bank Incorporation decisions in the historical notes section, and to provide other minor edits.
Banks and credit unions - consumer protection
- 2.3-102 Community Reinvestment Act (CRA) ratings policy
- This bulletin was updated for clarification on applicability to large banks and credit unions. Other language was streamlined for more clarity.
- 2.3-103 Alternative CRA examination procedures
- This bulletin was updated to incorporate Mortgage Lender Community Investment (MLCI) examinations conducted by the DOB at certain mortgage lenders. As it no applies to banks, credit unions, and licensees, this bulletin has been renumbered as 1.3-105. Other minor edits were made for clarification.
- School bank program
- This bulletin was updated to replace the application procedures with notice provisions, to eliminate the section relative to student banks, and to incorporate other minor revisions made necessary by the passage of Chapter 461 of the Acts of 2004. Additionally, the name of the bulletin was updated to Student Bank Programs.
- Certificate of deposit and money market account advertising guidelines
- This bulletin has been repealed in its entirety as sufficient and substantial consumer protection is available within state and federal laws governing the advertisement of deposit products, as well as unfair and deceptive and abusive acts and practices in advertising.
Credit unions only - risk management
- 4.2-101 Loan loss reserve requirements
- This bulletin has been repealed in its entirety because it is unnecessary given other accounting standards in effect. However, a letter to the credit union industry has been issued to clarify that such institutions still need to comply with such accounting standards despite the repeal of this bulletin.