WASHINGTON - Imagine being able to answer most of the questions on a bank charter application simply by checking "yes" or "no."
Or applying to open a new branch and, if your regulator fails to respond within 37 days, being allowed to go ahead and do it.
These banker fantasies and more will become reality soon as part of the Office of the Comptroller of Currency's continuing effort to make the national charter more attractive to banks.
The new "Comptroller's Corporate Manual," available in draft form this week, details the agency's planned expedited applications procedures and self-imposed deadlines, and includes many of the pared-down forms national banks will fill out in the future.
"I'm really excited about this," said Julie L. Williams, chief counsel for the Comptroller's office. "What it embodies is our effort to streamline the whole applications mechanism."
The centerpiece of the effort, introduced in the agency's "Part 5" regulation proposed last November, is special treatment for national banks that are well capitalized, have Camel ratings of 1 or 2, received at least a satisfactory rating on their most recent Community Reinvestment Act evaluation, and are not the object of an enforcement action.
These eligible national banks will have fewer forms to fill out and can expect a quicker turnaround from the Comptroller's office on applications to do such things as open or relocate branches. Eligible banks also won't have to get prior approval to invest up to 150% of their capital stock in bank premises. Possibly best of all, these banks will pay lower application fees.
"They're finally telling you that a Camel rating is worth something, that good management is worth something," said Diane Casey, regulatory director for the accounting firm of Grant Thornton in Washington. "It's a good thing."
The new corporate manual is still huge, at 871 pages. But its procedures and forms should take up half as much of national banks' time as those of the 1992 model, according to estimates provided to the Office of Management and Budget.
According to the Comptroller's office, the old forms took the country's 3,000 national banks 43,155 hours a year to fill out. The new ones will demand an estimated 22,343 hours.
How do they figure that? "It is ultimately a guesstimate," said agency spokeswoman Naomi Salus - though one based on historical data and the experiences of other regulatory agencies.
The Comptroller's office will be accepting comments on the draft manual until Sept. 15.
"If we have not put this together in a way that is as streamlined as we think it is, we need to know that," Ms. Williams said.
Copies of the manual have been sent to 33 national banks that file large numbers of applications. Others can request copies by contacting John Ference or Jessie Gates in the agency's legislative and regulatory activities division. The address is 250 E Street SW, Washington, D.C. 20219; or phone 202-874-5090.
