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The district has seen very favorable conditions; asset quality has increased and both problem assets and net loan losses have decreased. • Board risk parameters, adequacy of staffing, succession planning and audit. As a result, the OCC will focus on: • Identification, measurement, monitoring and control of interest risk rate.
In fact, in the intervening 23 years, the situation has arguably gotten even more complex as 31 states (plus the District of Columbia) have legalized cannabis consumption for either legal or medical reasons. I think there is a fundamental misunderstanding among supporters of this law of how riskmanagement systems work in banks.
Separately, eight attorneys general representing seven states and the District of Columbia have filed an action in federal district court in the Southern District of New York seeking to set aside the rule.
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