On June 12, the OCC issued Interpretive Letter 1185 confirming that national banks may use certain debt securities as collateral in repurchase (repo) agreements. In the letter, the OCC responded to a December 19, 2024, inquiry regarding whether customer-driven derivative transactions could be used as collateral for tri-party repos. The OCC stated that under the proposal, banks would act as borrowers in the repo transaction, selling collateral securities to a repo counterparty with an agreement to repurchase the securities at a predetermined time and price, and clarified that the use of equity securities in such repo transactions is not consistent with the OCC’s derivatives regulation.
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