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You work for a firm that represents ABC Bank, a major U.S. banking institution. The company's primary lines of business include banking, annuities, insurance and

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You work for a firm that represents ABC Bank, a major U.S. banking institution. The company's primary lines of business include banking, annuities, insurance and securities. ABC's CEO has contacted your law firm to help with a variety of issues pertaining to specific rules that have been passed by various administrative agencies. Your client believes that these rules are detrimental to ABC's business and wants to challenge each rule to the extent possible. Please draft a memo that identifies all potential issues with the following regulations and provide appropriate statutory and/or case law to support your position: Office of the Comptroller of the Currency (OCC) Minimum Savings Account Percentage Regulation : On January 1, the OCC published notice of a rule on its website requiring all banking institutions to provide a minimum interest rate on all savings accounts of 3%. As the OCC began receiving comments from the general public, it quickly realized that there were too many negative

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