Shelf Charter

On November 21, the OCC announced that it had granted its first conditional preliminary approval of a new type of national bank shelf-charter, designed to facilitate new equity investments in troubled depository institutions. The mechanism involves granting preliminary approval to investors for a national bank charter, which they can use when the opportunity arises to purchase a troubled bank.

Not Guilty

In a recent speech, Comptroller of the Currency John C. Dugan disagreed with suggestions that the Community Reinvestment Act (CRA) is partly responsible for the credit crisis. “CRA is not the culprit behind the subprime mortgage lending abuses, or the broader credit quality issues in the marketplace,” Dugan said in a speech to the Enterprise Annual Network Conference. “Indeed, the lenders most prominently associated with subprime mortgage lending abuses and high rates of foreclosure are lenders not subject to CRA.”