small loan ” exception to the flood insurance requirements from $ 5, 000 to $ 20, 000 and adjust this amount periodically based on changes in the consumer price index ; ( c ) reduce the forty - five - day waiting period required after policy expiration before a lender can “ force place ” flood insurance by fifteen days to coincide with the thirty - day grace period during which flood insurance coverage continues after policy expiration, which would better enable lenders to avoid gaps in coverage on the relevant collateral ; and ( d ) give the federal banking agencies discretion to impose civil money penalties on institutions found to have engaged in a pattern or practice of violating the flood insurance requirements. 17. periodic interagency review of call reports amendment requires that the federal banking agencies jointly review the call report forms at least once every five years to determine if some of the information required by the reports may be eliminated. the federal banking agencies would retain their current authority to determine what information must be included in the call reports filed by the institutions under their primary supervision. 18. ensure protection of confidential information received from foreign supervisory authorities amendment ensures that a federal banking agency may keep confidential information received from a foreign regulatory or supervisory authority if public disclosure of the information would violate the laws of the foreign country, and the banking agency obtained the information in connection with the administration and enforcement of federal banking laws or under a memorandum of understanding between the authority and the agency. the amendment would not authorize an agency to withhold information from congress or in response to a court order in an action brought by the united states or the agency. 19. restricting the ability of convicted individuals to participate in the affairs of a bank holding company or edge act or agreement corporation amendment would prohibit a person convicted of a criminal offense involving dishonesty, breach of trust, or money laundering from participating in the affairs of a bank holding company ( other than a foreign bank ) or an edge act or agreement corporation without the consent of the board. the amendment also would provide the board with greater discretion to prevent convicted individuals from participating in the affairs of a nonbank subsidiary of a bank holding company. 20. clarify application of section 8 ( i ) of the federal deposit insurance act amendment clarifies that a federal banking agency may take enforcement action against a person for conduct that occurred during his or her affiliation with a banking organization even if the person resigns from the organization, regardless of whether the enforcement action is initiated through a notice or an order.

federal reserve as required reserve balances. nonmember banks already are able to use such pass - through reserve accounts. 10. shorten the post - approval waiting period for bank mergers and acquisitions where the relevant banking agency and the attorney general agree the transaction will not have adverse competitive effects amendment allows the responsible federal banking agency, with the concurrence of the attorney general, to reduce the post - approval waiting periods under the bank merger act and bhc act from fifteen days to as few as five days. the amendment would not alter the time period that a private party has to challenge a banking agency ’ s approval of a transaction for reasons related to the community reinvestment act. 11. eliminate requirement that the reviewing agency request a competitive factors report from the other banking agencies in bank merger act transactions amendment would eliminate the requirement that the reviewing agency request a competitive factors report from the other banking agencies on bank merger act transactions. the reviewing agency would, however, continue to be required to ( i ) conduct a competitive analysis of the proposed merger, and ( ii ) request a competitive factors report from the attorney general and provide a copy of this request to the fdic ( when the fdic is not the reviewing agency ). 12. streamline bank merger act procedural requirements for transactions involving entities that are already under common control the amendment eliminates the need for the reviewing agency for a bank merger involving affiliated entities to request a report on the competitive factors associated with the transaction from the other banking agencies and the attorney general. the amendment also would eliminate the post - approval waiting period for bank merger act transactions involving affiliated entities. the merger of depository institutions that already are under common control typically does not have any impact on competition. 13. a. restore board ’ s authority to determine that new activities are “ closely related to banking ” and permissible for all bank holding companies amendment would restore the board ’ s ability to determine that nonbanking activities are “ closely related to banking ” under section 4 ( c ) ( 8 ) of the bhc act and, thus, permissible for all bank holding companies, including those that have not elected to become financial holding companies. bank holding companies would still have to become a financial holding company to engage in the types of expanded activities authorized by the glb act - including full - scope securities underwriting, insurance underwriting, and merchant banking activities - as well as any new activities that the board determines are financial in nature or incidental or complementary to financial activities