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OCC’s New System for Licensing and Public Welfare Investment Filings

November 08, 2016 / Source: OCC

OCC BULLETIN 2016-37
Subject: Central Application Tracking System
Date: November 7, 2016
To: Chief Executive Officers of All National Banks and Federal Savings Associations, Federal Branches and Agencies, Department and Division Heads, All Examining Personnel, and Other Interested Parties

Summary
Starting January 17, 2017, the Office of the Comptroller of the Currency (OCC) plans to roll out the new web-based Central Application Tracking System (CATS). CATS enables authorized national banks, federal savings associations (FSA),1 and federal branches and agencies (collectively, banks) to draft, submit, and track their licensing and public welfare investment applications and notices in a secure, electronic system. The system also allows OCC analysts to receive, process, and manage those applications and notices. CATS, which will be available through BankNet, replaces the existing e-Corp and CD-1 Invest application tools.
CATS, which the OCC piloted with a small number of banks earlier this year, will be rolled out in three phases to help banks transition from e-Corp and CD-1 Invest. Authorized third-party attorneys, consultants, and other contractors (agents) may draft filings in CATS and forward them to bank personnel, who can then submit them through CATS to the OCC. The OCC expects to allow these agents to submit filings through CATS, on behalf of banks, later in 2017. While the OCC strongly encourages banks to use CATS to submit filings as soon as they receive access to the system, banks can continue to submit paper filings.

Note for Community Banks
This bulletin applies to all OCC-supervised banks.

Highlights
Rollout Webinars and Schedule
Before rollout begins, OCC staff will present webinars to banks to explain how to register for and use CATS. The webinars will include time for questions and answers.
The rollout will take place in three phases. OCC staff will notify banks whether they are in phase 1, 2, or 3.

  • Phase 1: Begins January 17, 2017, for frequent e-Corp and CD-1 Invest filers
  • Phase 2: Begins spring 2017 for all remaining e-Corp and CD-1 Invest filers
  • Phase 3: Begins late spring 2017 for all remaining banks

User Roles in CATS
There are three bank user roles in CATS: drafter, submitter, and super user. The user roles provide a progression of responsibilities and authorities for bank staff involved in the bank’s filings. Banks must assign the appropriate user role to each member of their staffs who will use CATS. The users will then select their designated roles when registering for CATS, as discussed below. Each bank’s BankNet agent will need to authorize each user and the selected role.
CATS Access
Bankers will access CATS through BankNet, which is the secure portal for OCC-regulated banks. Bankers who use e-Corp or CD-1 Invest or otherwise are registered BankNet users will only need to register for CATS. Bankers who are not registered BankNet users will need to register for both BankNet and CATS. The OCC requests that banks wait until the start of their designated rollout phase to register for CATS. After registering for CATS, bankers should discontinue using e-Corp and CD-1 Invest, because banks will lose access to these two applications two weeks after their particular phase begins.
Resources and Technical Assistance
The CATS home page on BankNet contains several resources that CATS users should review before registering for CATS, including the Quick Start Card for Bankers, CATS Applicant User Manual, and e-Learning training. These resources explain the registration process, the three bank user roles, and overall system navigation and functions.
For technical assistance with BankNet and CATS, please call the BankNet Help Desk at (800) 641-5925 or e-mail BankNet@occ.treas.gov.
For specific questions about licensing or public welfare investment forms, filings, or processes, please contact the appropriate District Licensing or Community Affairs staff.
Further Information
Please contact John O’Brien, CATS Lead Expert, Licensing Division, at (312) 360-8863, or Jason Bouleris, Technical Assistant, Community Affairs Division, at (202) 649-6430.
 
Stephen A. Lybarger
Deputy Comptroller for Licensing
Barry R. Wides
Deputy Comptroller for Community Affairs