The OCC has made clear in a new interpretive letter that it will block charter conversions when it believes that these pose supervisory concerns. This issue has become a significant one as federal savings associations come under OCC supervision in the wake of Dodd-Frank’s elimination of the Office of Thrift Supervision. Fearful of more rigorous supervisory examinations and, over time, tougher OCC rules, numerous federal thrifts are exploring charter-conversion options that are complicated or even barred by the OCC under the criteria detailed in this interpretive letter.

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