OCC Releases Revised Comptroller’s Licensing Manual

On Monday, May 8, 2017, the OCC issued the “Fiduciary Powers” booklet of the Comptroller’s Licensing Manual. This revised booklet replaces the booklet of the same title issued in June of 2002. The new edition incorporates updated procedures and requirements following the integration of the Office of Thrift Supervision into the OCC in 2011 and the issuance of revised regulations (12 CFR 5), effective July 1, 2015, addressing applications for national banks and federal savings associations proposing to exercise fiduciary powers.


The revised “Fiduciary Powers” booklet:

  • Provides an overview of policies and decision criteria the OCC considers when reviewing applications from banks seeking to exercise fiduciary powers;
  • Provides guidance on application requirements and explains under which circumstances an expedited review is granted;
  • Outlines when a notice to the OCC may be required when a bank opens a fiduciary office in a new state;
  • Discusses procedures for a bank to surrender fiduciary powers, or for the OCC to revoke a bank’s fiduciary powers; and
  • Lists references and links to informational resources and sample forms and documents that applicants may find useful during the filing process.