The Banking Agencies’ Proposed Rule on Supervisory Guidance: Six Things To Know

On Tuesday, October 20, 2020, the Federal Deposit Insurance Corporation issued a proposed rule that would supersede and codify, with certain changes described below, a 2018 Interagency Statement Clarifying the Role of Supervisory Guidance (the “2018 Statement”). Like the 2018 Statement, the proposed rule would be adopted on an interagency basis with the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the National Credit Union Administration, and the Bureau of Consumer Financial Protection (the “Agencies”). We have prepared a blackline of the changes in the proposed rule compared to the 2018 Statement.