OCC Regulations Affecting Bank Note Offerings Become Effective

On January 1, 2013, the new regulations of the Office of the Comptroller of the Currency (the "OCC") amending Part 16.6 of the OCC's securities offering rules became effective. These rules govern the exemption from OCC registration of certain types of offerings of bank notes. The amendments were designed to remove the references to credit ratings in Part 16.6.

The rule revisions may be found at the following link: http://www.gpo.gov/fdsys/pkg/FR-2012-06-13/html/2012-14169.htm.

Part 16.6 of the OCC Rules

Bank notes enjoy an exemption from registration under Section 3(a)(2) of the Securities Act of 1933 (the "Securities Act"). However, national banks and U.S. federal branches and agencies of non-U.S. banks are subject instead to the OCC's registration rules, which require OCC registration of bank note offerings unless an exemption is available.