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The letter requires prior OCC written determination for significant Plan deviations, including detailed impact assessments and specific risk areas, and mandates updated financial projections by February 15, 2024 based on actual performance as of December 31, 2023.",{"@graph":63,"@context":118},[64,80,101],{"@type":65,"itemListElement":66},"BreadcrumbList",[67,71,74,77],{"item":68,"name":69,"@type":70,"position":9},"https://docshare.wps.com","Home","ListItem",{"item":72,"name":10,"@type":70,"position":73},"https://docshare.wps.com/template/",2,{"item":75,"name":41,"@type":70,"position":76},"https://docshare.wps.com/template/letters/",3,{"item":78,"name":59,"@type":70,"position":79},"https://docshare.wps.com/template/supervisory-condition-letter-2024-01-notification-of-conditional-no-supervisory-objection/280374/",4,{"url":78,"name":59,"@type":81,"image":82,"author":87,"headline":59,"publisher":90,"fileFormat":93,"inLanguage":57,"description":61,"dateModified":94,"datePublished":95,"encodingFormat":93,"isAccessibleForFree":96,"interactionStatistic":97},"DigitalDocument",{"url":83,"@type":84,"width":85,"height":86},"https://docshare.wps.com/thumbnails/supervisory-condition-letter-2024-01-notification-of-conditional-no-supervisory-objection/280374.png","ImageObject",442,249,{"name":88,"@type":89},"Rowan","Person",{"url":68,"name":91,"@type":92},"DocShare","Organization","application/pdf","2026-10-19","2026-09-16",true,{"@type":98,"interactionType":99,"userInteractionCount":8},"InteractionCounter",{"@type":100},"ViewAction",{"@type":102,"mainEntity":103},"FAQPage",[104,110,114],{"name":105,"@type":106,"acceptedAnswer":107},"What is the OCC’s supervisory position on Vast Bank’s Capital and Strategic Plan?","Question",{"text":108,"@type":109},"The OCC has no supervisory objection to the Plan, but only subject to the conditions stated in the letter.","Answer",{"name":111,"@type":106,"acceptedAnswer":112},"What must the Bank do before making a significant deviation from the Plan?",{"text":113,"@type":109},"The Bank must not significantly deviate without the assigned OCC Supervisory Office’s prior written determination of no supervisory objection, and it must provide at least 60 days advance written notice including an impact assessment with specified analyses and evaluations.",{"name":115,"@type":106,"acceptedAnswer":116},"By when must financial projections in the Plan be updated, and on what basis?",{"text":117,"@type":109},"By February 15, 2024, using actual performance as of December 31, 2023 to incorporate updated results into the Plan.","https://schema.org",{"og:url":78,"og:type":120,"og:title":59,"og:site_name":91,"og:description":61},"article",{"robots":122,"canonical":78},"index,follow",{"doc_id":124,"site_id":56},280374,1791386770,{"code":4,"msg":5,"data":127},{"doc_id":124,"user_id":128,"nickname":88,"user_avatar":129,"doc_module":9,"category_id":40,"category_name":41,"doc_title":59,"doc_description":61,"doc_content":130,"file_id":131,"file_url":132,"file_type":133,"file_size":134,"view_count":8,"is_deleted":4,"is_public":9,"is_downloadable":9,"audit_status":9,"page_count":73,"language":135,"language_code":57,"site_id":56,"html_lang":57,"table_of_contents":136,"faqs":137,"seo_title":138,"seo_description":61,"update_tm":139,"read_time":9},1099514067415,"https://ap-avatar.wpscdn.com/avatar/100002539d78ffe74a7?x-image-process=image/resize,m_fixed,w_180,h_180&k=1779092875211072502","CUI//FSI  \nWashington, DC 20219  \nSupervisory Condition Letter \\#2024-01 February 2024  \nJanuary 23, 2024  \nVia Email  \nBoard of Directors Vast Bank, N.A.  \n110 N. Elgin Avenue Tulsa, OK 74120  \nRe: Notification of Conditional No Supervisory Objection to Capital and Strategic Plan  \nDear Members of the Board:  \nThe Office of the Comptroller of the Currency (OCC) is in receipt of the Capital and Strategic Plan (Plan) submitted by Vast Bank, Tulsa, Oklahoma (Bank) on December 21, 2023, in accordance with the requirements of Article V of the Consent Order (Order) dated October 23, 2023. The Plan includes initiatives, strategies, and framework that appear to meet the requirements of the Order. The purpose of this letter to the Board is to communicate that the OCC has no supervisory objection to the Plan subject to the following conditions:  \n1. Effective immediately, the Bank may not significantly deviate from the Plan without the assigned OCC Supervisory Office’s prior written determination of no supervisory objection. The Bank must provide the OCC at least 60 days advance, written notice of its intent to deviate significantly from the Plan. This notice must include a written assessment of the impact of such change on the Bank’s condition that includes a profitability analysis and an evaluation of the adequacy of the Bank’s organizational structure, staffing, management information systems, risk assessments, impact on Bank Secrecy Act/Anti-Money Laundering and Office of Foreign Assets Control, internal controls, and written policies and procedures to identify, measure, monitor, and control the risks associated with the change in the Plan. Changes that constitute a significant deviation from the Plan include, but are not limited to, implementation of: banking as a service (BaaS); blockchain-based digital wallet services; portable digital identity platform; payments platform; digital asset trading; asset registry;  \ncryptocurrency; or money service business processing/money transmitter services.  \nTo receive non objection, the Board and management must demonstrate that they  \nunderstand the risks involved and have established the appropriate risk management structure, and that the Bank has the resources and expertise to implement activities in a safe and sound manner.  \nAdditionally, other significant deviations may include changes in: marketing strategies, products and services, marketing partners, or acquisition channels; underwriting practices or standards, credit administration, account management strategies; collection strategies, partners, or operations; fee structure, pricing, or fee application methods; accounting processes or practices; funding strategies; or any other changes in personnel, operations, or external factors that may have a material impact on the Bank’s operations or financial performance. A determination of a material impact on the Bank’s operations or financial performance may include a single change or changes in aggregate.  \n2. No later than February 15, 2024, the Board and management must update financial projections in the Plan to incorporate actual performance as of December 31, 2023.  \nThe condition of this no supervisory objection is a condition “imposed in writing by a Federal banking agency in connection with any action on any application, notice, or other request” within the meaning of 12 USC 1818. As such, the conditions are enforceable under 12 USC 1818.  \nThis letter does not amend, suspend, waive, or terminate any provisions of the Order dated October 23, 2023. This letter and the activities and communications by OCC employees in connection with the Bank’s submission do not constitute a contract, express or implied, or anyother obligation binding upon the OCC, the United States, any agency or entity of the United States, or any officer or employee of the United States, and does not affect the ability of the OCC to exercise its supervisory, regulatory, and examination authorities under applicab","cbCaimg1lttQwOjM","https://ap.wps.com/l/cbCaimg1lttQwOjM","pdf",152136,"English","# Supervisory Condition Letter\n## No Supervisory Objection and Applicable Conditions\n## Condition 1: Restrictions on Significant Plan Deviations\n## Condition 2: Updated Financial Projections by February 15, 2024\n## Legal Effect and Limitations","[{\"question\":\"What is the OCC’s supervisory position on Vast Bank’s Capital and Strategic Plan?\",\"answer\":\"The OCC has no supervisory objection to the Plan, but only subject to the conditions stated in the letter.\"},{\"question\":\"What must the Bank do before making a significant deviation from the Plan?\",\"answer\":\"The Bank must not significantly deviate without the assigned OCC Supervisory Office’s prior written determination of no supervisory objection, and it must provide at least 60 days advance written notice including an impact assessment with specified analyses and evaluations.\"},{\"question\":\"By when must financial projections in the Plan be updated, and on what basis?\",\"answer\":\"By February 15, 2024, using actual performance as of December 31, 2023 to incorporate updated results into the Plan.\"}]","Supervisory Condition Letter - 2024-01 - Notification of Conditional No Supervisory Objection | PDF",1789538276]