On November 7, 2016, the Office of the Comptroller of the Currency (“OCC”) announced that the agency will begin phasing in a new, centralized online system for processing licensing and public welfare investment applications and notices filed by national banks, federal savings associations, and federal branches and agencies (collectively, “banks”).

The new Central Application Tracking System (“CATS”) will be available through BankNet, the agency’s existing page for interfacing with banks electronically, and will allow banks to grant different authorization levels to staff and authorized third-party agents involved in preparing OCC filings.

CATS will become available to “frequent” users of the existing e-Corp and CD-1 Invest systems on January 17, 2017, to other e-Corp and CD-1 Invest users in the spring of 2017, and to all other banks in late spring 2017.  The OCC will notify banks to which of the three categories they belong.  The OCC will retire e-Corp and CD-1 Invest on a similar rolling schedule, with access to these tools ending for each bank two weeks after that bank’s CATS access begins.  The agency will conduct CATS training webinars for BankNet users before the transition, and it will continue to accept paper filings.

Photo of Randy Benjenk Randy Benjenk

Randy Benjenk is a partner in Covington’s industry-leading Financial Services Group and focuses his practice on regulatory advice and advocacy. He represents domestic and foreign banks, fintech companies, and trade associations on compliance issues, corporate transactions, and public policy matters.

Chambers USA says…

Randy Benjenk is a partner in Covington’s industry-leading Financial Services Group and focuses his practice on regulatory advice and advocacy. He represents domestic and foreign banks, fintech companies, and trade associations on compliance issues, corporate transactions, and public policy matters.

Chambers USA says Randy has received “widespread praise” from clients, who describe him as “excellent” and say that “the quality of his legal work and his writing abilities were incredible” and “he’s very easy to work with, knowledgeable and efficient.”

Randy regularly advises clients on a wide range of regulatory matters, including:

  • Bank Activities and Prudential Regulation. Complex bank activities, structure, licensing, and prudential matters, often involving issues of first impression at the federal and state banking agencies.
  • Corporate Transactions. Mergers and acquisitions, spinoffs, charter conversions, debt and equity issuances, investments, strategic partnerships, de novo bank formations, and related regulatory applications and disclosures.
  • Private Equity Investments. Private equity investments in banks, bank investments in private funds, and fund structuring related to the Volcker Rule and Bank Holding Company Act.
  • Public Policy Matters. Regulatory and legislative policy matters, with an emphasis on changes arising out of U.S. banking legislation and international standards.
  • Crisis Response. Navigating extraordinary events, such as the COVID-19 pandemic and related governmental responses, and firm-specific matters.
  • Supervisory and Enforcement Matters. Compliance and safety and soundness issues that arise in the examination and enforcement contexts.
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