On 2 July 2014, the OCC, the Federal Reserve Board and the FDIC jointly issued an addendum to the Interagency Policy Statement on Income Tax Allocation in a Holding Company Structure applicable to all OCC-supervised institutions in a holding company structure. The addendum was issued to ensure that insured depository institutions (“IDIs”) in a consolidated group maintain appropriate relationships regarding the payment of taxes and treatment of tax refunds. The addendum requires that IDIs and their holding companies ensure that their tax-allocation agreements (i) expressly state that the holding companies are agents for the IDIs and (ii) are consistent with the requirements of Sections 23A and 23B of the Federal Reserve Act.

The full text of the interagency addendum is available at: http://www.gpo.gov/fdsys/pkg/FR-2014-06-19/pdf/2014-14325.pdf.