Collective Investment Funds

Special Exemption Funds

The OCC’s CIF regulations include a procedure under 12 CFR 9.18(c)(5) for the OCC to consider new types of funds, and to consider modifications to existing types of funds. With OCC approval, banks are provided a means to operate an A1 or A2 fund and not comply with some or all of the provisions of sections 9.18(a) and (b). Since the issuance of revised part 9 in 1996, however, the OCC has had few occasions to issue “(c)(5)” interpretive letters. This is because section 9.18 is a permissive regulation that, in most situations, authorizes a particular CIF activity “where consistent with applicable law.”

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