2020-11-05 | 2020-24484The OCC, Board, FDIC, NCUA, and Bureau propose to codify the 2018 Interagency Statement Clarifying the Role of Supervisory Guidance to confirm that such guidance does not create binding legal obligations for the public. The proposed rule reinforces that supervisory guidance lacks the force and effect of law while simultaneously making the Statement itself binding on the issuing agencies. This action aims to ensure agencies respect administrative law limits in carrying out supervisory responsibilities and to provide clarity regarding the non-binding nature of supervisory expectations.