Part 34, Subpart E (OREO) / Holding Period (§ 34.82)
By: Stephen Rountree
As of December 1, 2019, The OCC will adopt and amended its regulations pertaining to Other Real Estate Owned (OREO). Amongst the chief change is the holding period for OREO for Federal savings banks. The change will establish the same holding period for National banks as well as FSBs. In short:
The final rule establishes an initial holding period for Federal savings associations of five years after commencement of the holding period to ensure the safe and sound management of OREO holdings. If the Federal savings association has not disposed of the OREO within the initial five-year holding period, the savings association may request OCC approval to continue to hold the real property as OREO for up to five additional years. These provisions are consistent with the rules that apply to national banks.
For additional details regarding Part 34 E changes, please refer to:
https://www.federalregister.gov/d/2019-22823/p-3
Please refer to the Q1 2019 Newsletter for discussion of OREO holding periods for State chartered institutions.
The final rule establishes an initial holding period for Federal savings associations of five years after commencement of the holding period to ensure the safe and sound management of OREO holdings. If the Federal savings association has not disposed of the OREO within the initial five-year holding period, the savings association may request OCC approval to continue to hold the real property as OREO for up to five additional years. These provisions are consistent with the rules that apply to national banks.
For additional details regarding Part 34 E changes, please refer to:
https://www.federalregister.gov/d/2019-22823/p-3
Please refer to the Q1 2019 Newsletter for discussion of OREO holding periods for State chartered institutions.