Notice2023-25744
Agency Information Collection Activities: Revision of an Approved Information Collection; Comment Request; Capital Adequacy Standards
Primary source
Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.
Published
November 21, 2023
Issuing agencies
Treasury DepartmentComptroller of the Currency
Abstract
The OCC, as part of its continuing effort to reduce paperwork and respondent burden, invites comment on a continuing information collection, as required by the Paperwork Reduction Act of 1995 (PRA). In accordance with the requirements of the PRA, the OCC may not conduct or sponsor, and the respondent is not required to respond to, an information collection unless it displays a currently valid Office of Management and Budget (OMB) control number. The OCC is soliciting comment concerning a revision to its information collection titled, "Capital Adequacy Standards."
Full Text
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<title>Federal Register, Volume 88 Issue 223 (Tuesday, November 21, 2023)</title>
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[Federal Register Volume 88, Number 223 (Tuesday, November 21, 2023)]
[Notices]
[Pages 81176-81180]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2023-25744]
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DEPARTMENT OF THE TREASURY
Office of the Comptroller of the Currency
Agency Information Collection Activities: Revision of an Approved
Information Collection; Comment Request; Capital Adequacy Standards
AGENCY: Office of the Comptroller of the Currency (OCC), Treasury.
ACTION: Notice and request for comment.
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SUMMARY: The OCC, as part of its continuing effort to reduce paperwork
and respondent burden, invites comment on a continuing information
collection, as required by the Paperwork Reduction Act of 1995 (PRA).
In accordance with the requirements of the PRA, the OCC may not conduct
or sponsor, and the respondent is not required to respond to, an
information collection unless it displays a currently valid Office of
Management and Budget (OMB) control number. The OCC is soliciting
comment concerning a revision to its information collection titled,
``Capital Adequacy Standards.''
DATES: Comments must be received by January 22, 2024.
ADDRESSES: Commenters are encouraged to submit comments by email, if
possible. You may submit comments by any of the following methods:
<bullet> Email: <a href="/cdn-cgi/l/email-protection#d3a3a1b2babdb5bc93bcb0b0fda7a1b6b2a0fdb4bca5"><span class="__cf_email__" data-cfemail="84f4f6e5edeae2ebc4ebe7e7aaf0f6e1e5f7aae3ebf2">[email protected]</span></a>.
<bullet> Mail: Chief Counsel's Office, Attention: Comment
Processing, Office of the Comptroller of the Currency, Attention: 1557-
0318, 400 7th Street SW, Suite 3E-218, Washington, DC 20219.
<bullet> Hand Delivery/Courier: 400 7th Street SW, Suite 3E-218,
Washington, DC 20219.
<bullet> Fax: (571) 293-4835.
Instructions:You must include ``OCC'' as the agency name and
``1557-0318'' in your comment. In general, the OCC will publish
comments on <a href="http://www.reginfo.gov">www.reginfo.gov</a> without change, including any business or
personal information provided, such as name and address information,
email addresses, or phone numbers. Comments received, including
attachments and other supporting materials, are part of the public
record and subject to public disclosure. Do not include any information
in your comment or supporting materials that you consider confidential
or inappropriate for public disclosure.
Following the close of this notice's 60-day comment period, the OCC
will publish a second notice with a 30-day comment period. You may
review comments and other related materials that pertain to this
information collection beginning on the date of publication of the
second notice for this collection by the method set forth in the next
bullet.
<bullet> Viewing Comments Electronically: Go to <a href="http://www.reginfo.gov">www.reginfo.gov</a>.
Hover over the ``Information Collection Review'' drop down menu. Click
on ``Information Collection Review.'' From the ``Currently under
Review'' drop-down menu, select ``Department of Treasury'' and then
click ``submit.'' This information collection can be located by
searching OMB control number ``1557-0318'' or ``Capital Adequacy
Standards.'' Upon finding the appropriate information collection, click
on the related ``ICR Reference Number.'' On the next screen, select
``View Supporting Statement and Other Documents'' and then click on the
link to any comment listed at the bottom of the screen.
<bullet> For assistance in navigating <a href="http://www.reginfo.gov">www.reginfo.gov</a>, please
contact the Regulatory Information Service Center at (202) 482-7340.
[[Page 81177]]
FOR FURTHER INFORMATION CONTACT: Shaquita Merritt, Clearance Officer,
(202) 649-5490, Chief Counsel's Office, Office of the Comptroller of
the Currency, 400 7th Street SW, Washington, DC 20219. If you are deaf,
hard of hearing, or have a speech disability, please dial 7-1-1 to
access telecommunications relay services.
SUPPLEMENTARY INFORMATION: Under the PRA (44 U.S.C. 3501 et seq.),
Federal agencies must obtain approval from the OMB for each collection
of information that they conduct or sponsor. ``Collection of
information'' is defined in 44 U.S.C. 3502(3) and 5 CFR 1320.3(c) to
include agency requests or requirements that members of the public
submit reports, keep records, or provide information to a third party.
Section 3506(c)(2)(A) of title 44 generally requires Federal agencies
to provide a 60-day notice in the Federal Register concerning each
proposed collection of information, including each proposed extension
of an existing collection of information, before submitting the
collection to OMB for approval. To comply with this requirement, the
OCC is publishing notice of the revision to the collection of
information set forth in this document. The OCC asks OMB to approve
this revised collection.
Title: Capital Adequacy Standards. OMB Control No.: 1557-0318.
Type of Review: Regular.
Abstract: The OCC is seeking renewal with revision of an
information collection approval for the recordkeeping, reporting, and
disclosure requirements associated with capital adequacy standards
applicable to national banks and Federal savings associations. The OCC
is proposing revisions in connection with this extension to reflect
more granular detail for certain existing reporting and recordkeeping
provisions, as well as improving prior estimates regarding the number
of respondents and burden associated with these existing provisions. In
addition, reporting burden associated with 12 CFR 3.304 is being
removed as that portion of the rule is no longer in effect.
Section-by-Section Analysis
Twelve CFR part 3 sets forth the OCC's minimum capital requirements
and overall capital adequacy standards for national banks and Federal
savings associations.
Minimum Regulatory Capital Ratios
Reporting Requirements
Section 3.3(c) allows for the recognition of netting across
multiple types of transactions or agreements if the national bank or
Federal savings association obtains a written legal opinion verifying
the validity and enforceability of the agreement under certain
circumstances.
Section 3.22(b)(2)(iv) permits, with prior notice to the OCC, a
national bank or Federal savings association resulting from a merger,
acquisition, or purchase transaction and that is not an advanced
approaches national bank or Federal savings association to change its
AOCI opt-out election.
Section 3.22(c)(4) provides that, with the prior written approval
of the OCC, a national bank or Federal savings association that
underwrites a failed underwriting, is not required to deduct an
investment in the capital of an unconsolidated financial institution to
the extent the investment is related to the failed underwriting.
Section 3.22(c)(5)(i) provides that, with the prior written
approval of the OCC, an advanced approaches national bank or Federal
savings association that underwrites a failed underwriting, for the
period of time stipulated by the OCC is not required to deduct from
capital a non-significant investment in the capital of an
unconsolidated financial institution or an investment in a covered debt
instrument to the extent the investment is related to the failed
underwriting.
Section 3.22(c)(6) provides that, with prior written approval of
the OCC and for the period of time stipulated by the OCC, an advanced
approaches national bank or Federal savings association that
underwrites a failed underwriting is not required to deduct the
significant investment in the capital of an unconsolidated financial
institution or an investment in a covered debt instrument if such
investment is related to such failed underwriting.
Section 3.22(d)(2)(i)(C) provides that, with the prior written
approval of the OCC and for the period of time stipulated by the OCC,
an advanced approaches national bank or Federal savings association
that underwrites a failed underwriting is not required to deduct a
significant investment in the capital of an unconsolidated financial
institution in the form of common stock if such investment is related
to such failed underwriting.
Section 3.22(d)(2)(iii) permits an advanced approaches national
bank or Federal savings association to change its exclusion preference
to exclude deferred tax assets (DTAs) and deferred tax liabilities
(DTLs) relating to adjustments relating to common equity tier 1 capital
after obtaining the prior approval of the OCC.
Section 3.22(h)(2)(iii)(A) permits the use of a conservative
estimate of the amount of an institution's investment in its own
capital or the capital of unconsolidated financial institutions held
through an index security with prior approval by the OCC.
Recordkeeping Requirements
Section 3.3(d) allows for the recognition of an agreement as a
qualifying master netting agreement if the national bank or Federal
savings association conducts a sufficient legal review and maintains
sufficient written documentation of that legal review to ensure that
the agreement continues to satisfy the requirements of the definition
of qualifying master netting agreement that a relevant court would find
to be legal, valid, binding, and enforceable. Section 3.3(d) further
requires s national banks and Federal savings associations to establish
and maintain written procedures to monitor possible changes in relevant
law and to ensure that the agreement continues to satisfy the
requirements of the definition of qualifying master netting agreement.
Standardized Approach
Reporting Requirements
Section 3.37(c)(4)(i)(E) requires that a bank or Federal savings
association obtain the prior approval of the OCC for and notify the OCC
if it makes any material changes to the policies and procedures
describing how it determines the period of significant financial stress
used to calculate its own internal estimates for haircuts and be able
to provide empirical support for the period used.
Recordkeeping Requirements
Section 3.35(b)(3)(i)(A) requires for a cleared transaction with a
qualified central counterparty (QCCP), that a client bank apply a risk
weight of two percent, provided that the collateral posted by the
national bank or Federal savings association to the QCCP is subject to
certain arrangements and the client bank has conducted a sufficient
legal review (and maintains sufficient written documentation of the
legal review) to conclude with a well-founded basis that the
arrangements, in the event of a legal challenge, would be found to be
legal, valid, binding, and enforceable under the law of the relevant
jurisdictions.
Section 3.37(c)(4)(i)(E) requires that a national bank or Federal
savings association have policies and procedures in place describing
how it determines the period of significant
[[Page 81178]]
financial stress used to calculate its own internal estimates for
haircuts and be able to provide empirical support for the period used.
Section 3.41(b)(3), which sets forth operational requirements for
securitization exposures, allows a national bank or Federal savings
association to recognize for risk-based capital purposes, in the case
of synthetic securitizations, a credit risk mitigant to hedge
underlying exposures if certain conditions are met. Section 3.41(b)(3)
includes a requirement that the national bank or Federal savings
association obtain a well-reasoned opinion from legal counsel that
confirms the enforceability of the credit risk mitigant in all relevant
jurisdictions.
Section 3.41(c)(2)(i) requires that a national bank or Federal
savings association demonstrate its comprehensive understanding of a
securitization exposure by conducting an analysis of the risk
characteristics of each securitization exposure prior to its
acquisition, taking into account a number of specified considerations
and documenting the analysis within three business days after the
acquisition.
Section 3.41(c)(2)(ii) requires a national bank or Federal savings
association, on an on-going basis (no less frequently than quarterly),
to evaluate, review, and update as appropriate the analysis required
under Sec. 3.41(c)(1) for each securitization exposure.
Disclosure Requirements
In a case where a national bank or Federal savings association
provides non-contractual support (i.e., implicit support) to a
securitization, Sec. 3.42(e)(2) requires the national bank or Federal
savings association to publicly disclose that it has provided implicit
support to the securitization and the risk-based capital impact to the
bank or savings association of providing such implicit support.
Section 3.62 sets forth disclosure requirements related to the
capital requirements of a national bank or Federal savings association.
Section 3.61 provides that these requirements apply to an institution
with total consolidated assets of $50 billion or more that is not a
consolidated subsidiary of a bank holding company, savings and loan
holding company, or a depository institution subject to the disclosure
requirements of Sec. 3.62. For national banks or Federal savings
associations subject to the disclosure requirements, Sec. 3.62(a)
requires quarterly disclosure of information in the applicable tables
in Sec. 3.63 and, if a significant change occurs, such that the most
recent reported amounts are no longer reflective of the institution's
capital adequacy and risk profile, Sec. 3.62(a) requires the national
bank or Federal savings association to disclose as soon as practicable
thereafter a brief discussion of the change and its likely impact.
Section 3.62(a) also permits annual disclosure of qualitative
information that typically does not change each quarter, provided that
any significant changes are disclosed in the interim.
Section 3.62(b) requires that a national bank or Federal savings
association have a formal disclosure policy approved by the board of
directors that addresses its approach for determining the disclosures
it makes. The policy must address the associated internal controls and
disclosure controls and procedures. Section 3.62(c) permits a national
bank or Federal savings association to disclose more general
information about certain subjects if the national bank or Federal
savings association concludes that the specific commercial or financial
information required to be disclosed under Sec. 3.62 is exempt from
disclosure under the Freedom of Information Act (5 U.S.C. 552) and the
national bank or Federal savings association provides the reason the
specific items of information have not been disclosed.
Currently, Sec. 3.63 sets forth the specific disclosure
requirements for a non-advanced approaches national bank or Federal
savings association with total consolidated assets of $50 billion or
more that is not a consolidated subsidiary of a bank holding company,
savings and loan holding company, or a depository institution subject
to the disclosure requirements of Sec. 3.62. Section 3.63(a) requires
those institutions to make the disclosures in Tables 1 through 10 in
Sec. 3.63 and in Sec. 3.63(b) for each of the last three years
beginning on the effective date of the rule. Section 3.63(b) requires
quarterly disclosure of an institution's common equity tier 1 capital,
additional tier 1 capital, tier 2 capital, tier 1 and total capital
ratios, including the regulatory capital elements and all the
regulatory adjustments and deductions needed to calculate the numerator
of such ratios; total risk-weighted assets, including the different
regulatory adjustments and deductions needed to calculate total risk-
weighted assets; regulatory capital ratios during any transition
periods, including a description of all the regulatory capital elements
and all regulatory adjustments and deductions needed to calculate the
numerator and denominator of each capital ratio during any transition
period; and a reconciliation of regulatory capital elements as they
relate to its balance sheet in any audited consolidated financial
statements. Tables 1 through 10 in Sec. 3.63 set forth qualitative
and/or quantitative requirements for scope of application, capital
structure, capital adequacy, capital conservation buffer, credit risk,
counterparty credit risk-related exposures, credit risk mitigation,
securitizations, equities not subject to Subpart F (Market Risk
requirements) of the rule, and interest rate risk for non-trading
activities.
Advanced Approaches
Reporting Requirements
Section 3.121(b)(2) requires a national bank or Federal savings
association to submit an implementation plan, together with a copy of
the minutes of the board of director's approval, to the OCC at least 60
days before the national bank or Federal savings association proposes
to begin its parallel run, unless the OCC waives prior notice.
Section 3.121(c) requires that during a parallel run, a national
bank or Federal savings association report to the OCC on a calendar
quarterly basis its risk-based capital ratios.
Section 3.122(d)-(g) requires a national bank or Federal savings
association to obtain the prior written approval of the OCC under Sec.
3.132 to use the internal models methodology for counterparty credit
risk and the advanced CVA approach for the CVA capital requirement,
Sec. 3.135 to use the double default treatment, Sec. 3.153 to use the
internal models approach for equity exposures, and Sec. 3.122(g)(3) to
generate an estimate of its operational risk exposure using an
alternative approach.
Section 3.123 references ongoing qualification requirements that
would require an institution to notify the OCC of any material change
to an advance system and establish and submit to the OCC a plan for
returning to compliance with the qualification requirements.
Section 3.124 requires a national bank or Federal savings
association to submit to the OCC, within 90 days of consummating a
merger or acquisition, an implementation plan for using its advanced
systems for the merged or acquired company.
Section 3.132(b)(2)(iii)(A) addresses counterparty credit risk of
repo-style transactions, eligible margin loans, and over-the-counter
(OTC) derivative contracts, and internal estimates for haircuts. With
the prior written approval of the OCC, a national bank or Federal
savings association may calculate haircuts using its own internal
estimates of the volatilities of market
[[Page 81179]]
prices and foreign exchange rates. The section requires national banks
and Federal savings associations to satisfy certain minimum
quantitative standards in order to receive OCC approval to use its own
internal estimates.
Section 3.132(b)(3) covers counterparty credit risk of repo-style
transactions, eligible margin loans, OTC derivative contracts, and
simple Value-at-Risk (VaR) methodology. With the prior written approval
of the OCC, a national bank or Federal savings association may estimate
exposure at default (EAD) for a netting set using a VaR model that
meets certain requirements.
Section 3.132(d)(1) permits the use of the internal models
methodology (IMM) to determine EAD for counterparty credit risk for
derivative contracts with prior written approval from the OCC.
Section 3.132(d)(1)(iii) permits the use of the internal models
methodology for derivative contracts, eligible margin loans, and repo-
style transactions subject to a qualifying cross-product netting
agreement with prior written approval from the OCC.
Section 3.132(d)(2)(iv) addresses counterparty credit risk of repo-
style transactions, eligible margin loans, and OTC derivative
contracts, and risk-weighted assets using IMM. Under the IMM, an
institution uses an internal model to estimate the expected exposure
(EE) for a netting set and then calculates EAD based on that EE. A
national bank or Federal savings association must calculate two EEs and
two EADs (one stressed and one unstressed) for each netting as outlined
in this section. A national bank or Federal savings association may use
a conservative measure of EAD subject to prior written approval of the
OCC.
Section 3.153(b), outlining the Internal Models Approach (IMA) for
calculating risk-weighted assets for equity exposures, specifies that a
national bank or Federal savings association must receive prior written
approval from the OCC before it can use IMA by demonstrating to the OCC
that the national bank or Federal savings association meets certain
criteria.
Recordkeeping Requirements
Section 3.121 requires a national bank or Federal savings
association subject to the advanced approaches risk-based capital
requirements to adopt a written implementation plan to address how it
will comply with the advanced capital adequacy framework's
qualification requirements and also develop and maintain a
comprehensive and sound planning and governance process to oversee the
implementation efforts described in the plan. Section 3.122 further
requires these institutions to: develop processes for assessing capital
adequacy in relation to an organization's risk profile; establish and
maintain internal risk rating and segmentation systems for wholesale
and retail risk exposures, including comprehensive risk parameter
quantification processes and processes for annual reviews and analyses
of reference data to determine their relevance; document their
processes for identifying, measuring, monitoring, controlling, and
internally reporting operational risk; verify the accurate and timely
reporting of risk-based capital requirements; and monitor, validate,
and refine their advanced systems.
Section 3.132(d)(3)(vi) addresses counterparty credit risk of repo-
style transactions, eligible margin loans, and OTC derivative
contracts. To obtain OCC approval to calculate the distributions of
exposures upon which the EAD calculation is based, a national bank or
Federal savings association must demonstrate to the satisfaction of the
OCC that it has been using for at least one year an internal model that
broadly meets the minimum standards with which the national bank or
Federal savings association must maintain compliance. The national bank
or Federal savings association must have procedures to identify,
monitor, and control wrong-way risk throughout the life of an exposure
and they must include stress testing and scenario analysis.
Section 3.132(d)(3)(viii) addresses counterparty credit risk of
repo-style transactions, eligible margin loans, and OTC derivative
contracts. When estimating model parameters based on a stress period, a
national bank or Federal savings association must use at least three
years of historical data that include a period of stress to the credit
default spreads of its counterparties. The national bank or Federal
savings association must review the data set and update the data as
necessary, particularly for any material changes in its counterparties.
The national bank or Federal savings association must demonstrate at
least quarterly that the stress period coincides with increased credit
default swap (CDS) or other credit spreads of the institution's
counterparties. The national bank or Federal savings association must
have procedures to evaluate the effectiveness of its stress calibration
that include a process for using benchmark portfolios that are
vulnerable to the same risk factors as the national bank's or Federal
savings association's portfolio. The OCC may require the institution to
modify its stress calibration to better reflect actual historic losses
of the portfolio.
Section 3.132(d)(3)(ix), regarding counterparty credit risk of
repo-style transactions, eligible margin loans, and OTC derivative
contracts, requires that a national bank or Federal savings association
must subject its internal model to an initial validation and annual
model review process that includes consideration of whether the inputs
and risk factors, as well as the model outputs, are appropriate. The
section requires national banks and Federal savings associations to
have a backtesting program for its model that includes a process by
which unacceptable model performance will be determined and remedied.
Section 3.132(d)(3)(x), regarding counterparty credit risk of repo-
style transactions, eligible margin loans, and OTC derivative
contracts, provides that a national bank or Federal savings association
must have policies for the measurement, management, and control of
collateral and margin amounts.
Section 3.132(d)(3)(xi), concerning counterparty credit risk of
repo-style transactions, eligible margin loans, and OTC derivative
contracts, states that a national bank or Federal savings association
must have a comprehensive stress testing program that captures all
credit exposures to counterparties and incorporates stress testing of
principal market risk factors and creditworthiness of counterparties.
Section 3.133(b)(3)(i)(A) permits a national bank or Federal
savings association to assign a two percent risk weight to an exposure
to a qualifying central counterparty (QCCP), if the institution
conducts sufficient legal review, and maintains written documentation
of that review.
Section 3.141(b)(3) requires a national bank or Federal savings
association to obtain a well-reasoned legal opinion confirming the
enforceability of the credit risk mitigant in all relevant
jurisdictions in order to recognize the transference of risk in
connection with a synthetic securitization.
Sections 3.141(c)(1) and 3.141(c)(2)(i) require a national bank or
Federal savings association to demonstrate its comprehensive
understanding of a securitization exposure for each securitization
exposure by conducting an analysis of the risk characteristics of a
securitization exposure prior to acquiring the exposure and document
such analysis within three business days after acquiring the exposure.
Section 3.141(c)(2)(ii) requires that institutions, on an on-going
basis (at least quarterly), evaluate, review, and update as appropriate
the analysis
[[Page 81180]]
required under this section for each securitization exposure.
Disclosure Requirements
Section 3.142, which outlines the capital treatment for
securitization exposures, requires a national bank or Federal savings
association to disclose publicly that it has provided implicit support
to a securitization and the regulatory capital impact to the
institution of providing such implicit support. Specifically, Sec.
3.124(a) requires a national bank or Federal savings association that
merges with or acquires a company that does not calculate its risk-
based capital requirements using advanced systems and uses subpart D to
determine the risk-weighted asset amounts for the merged or acquired
company's exposures, the national bank or Federal savings association
must disclose publicly the amounts of risk-weighted assets and
qualifying capital calculated under this subpart for the bank or
savings association and under subpart D for the acquired company.
Section 3.172 specifies that each national bank or Federal savings
association that is an advanced approaches national bank or Federal
savings association, that has completed the parallel run process, must
publicly disclose its total and tier 1 risk-based capital ratios and
their components.
Section 3.173 addresses disclosures by an advanced approaches
national bank or Federal savings association that is not a consolidated
subsidiary of a bank holding company, savings and loan holding company,
or a depository institution subject to the disclosure requirements of
Sec. 3.172. An advanced approaches institution that is subject to the
disclosure requirements must make the disclosures described in Sec.
3.173, Tables 1 through 12. The national bank or Federal savings
association must make these disclosures publicly available for each of
the last three years (that is, twelve quarters) or such shorter period
beginning on the effective date of this subpart E. The tables in Sec.
3.173 require qualitative and quantitative public disclosures for
capital structure, capital adequacy, capital conservation and
countercyclical buffers, general disclosures related to credit risk,
credit risk disclosures for portfolios subject to IRB risk-based
capital formulas, general disclosures related to counterparty credit
risk of OTC derivative contracts, repo-style transactions, and eligible
margin loans, credit risk mitigation, securitization, operational risk,
equities not subject to the market risk capital requirements, and
interest rate risk for non-trading activities.
Burden Estimates
Estimated Number of Respondents: 1,014 national banks and Federal
savings associations.\1\
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\1\ Respondents represent all active national banks and Federal
savings associations as of September 30, 2023.
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Estimated Total Annual Burden Hours: 87,087.
Comments submitted in response to this notice will be summarized
and included in the request for OMB approval. All comments will become
a matter of public record. Comments are invited on:
(a) Whether the collection of information is necessary for the
proper performance of the functions of the OCC, including whether the
information has practical utility;
(b) The accuracy of the OCC's estimate of the burden of the
collection of information;
(c) Ways to enhance the quality, utility, and clarity of the
information to be collected;
(d) Ways to minimize the burden of the collection on respondents,
including through the use of automated collection techniques or other
forms of information technology; and
(e) Estimates of capital or start-up costs and costs of operation,
maintenance, and purchase of services to provide information.
Theodore J. Dowd,
Deputy Chief Counsel, Office of the Comptroller of the Currency.
[FR Doc. 2023-25744 Filed 11-20-23; 8:45 am]
BILLING CODE 4810-33-P
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</html>Indexed from Federal Register on November 21, 2023.
This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.