After reviewing the proposal’s statutory basis, coverage, and operative requirements, Mr. Court explains the basis for BPI’s position that the proposal is inconsistent with how banking is regularly conducted and will undermine rather than promote safety and soundness, provides examples of how the proposal would impose unworkable requirements, and discusses BPI’s Freedom of Information Act request to the OCC for data supporting its assertions about banks in the proposal. Ballard Spahr attorney Alan Kaplinsky hosts the conversation with Mr. Court.

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