Legal Interpretations
Bank Holding Company/Change in Control - 2008 Letters
December 22, 2008 (PDF)
Letter to James S. Keller granting an exemption from the Board's risk-based capital guidelines for bank holding companies (12 CFR Part 225, App. A) to permit The PNC Financial Services Group, Inc., to include in tier 1 capital certain deferred tax assets acquired in connection with its purchase of National City Corporation.
December 5, 2008 (PDF)
Letter to Robert L. Tortoriello approving the notice by BNP Paribas, Paris, France, to enter into physically settled tolling agreements with power plant owners and to provide energy management services to power plant owners in the United States, indirectly through its proposed subsidiary, Fortis Bank S.A./N.V., Brussels, Belgium.
November 26, 2008 (PDF)
Letter to Arthur S. Long, Esq., approving the acquisition under section 3 of the Bank Holding Company Act (12 U.S.C. section 1842) by UK Financial Investments Limited of an indirect controlling interest in the U.S. bank subsidiaries of The Royal Bank of Scotland and granting exemptions under section 4(c)(9) of the Bank Holding Company Act (12 U.S.C. section 1843(c)(9)) from the nonbanking restrictions of the Act.
August 5, 2008 (PDF)
Letter to H. Rodgin Cohen, Esq., granting the requests by China Investment Corporation and Central SAFE Investments Limited for exemptions under section 4(c)(9) of the Bank Holding Company Act (12 U.S.C. section 1843(c)(9)) from the nonbanking restrictions of the Act.
July 31, 2008 (PDF)
Letter to Gary Rice, Esq., allowing for the exercise of an option, previously approved by Board order, for voting shares of Israel Discount Bank, Tel Aviv, Israel, the parent of Israel Discount Bank of New York, New York, by two ownership groups without the filing of an application to the Board under the Bank Holding Company Act.
June 19, 2008 (PDF)
Letter to John R. Jay granting an exemption from the Board's risk-based capital guidelines for bank holding companies and state member banks (12 CFR parts 208 and 225, App. A) to permit SunTrust Banks, Inc. and SunTrust Bank to include in their tier 1 capital certain unrealized gains on AFS equity securities as a result of certain collateralized forward contracts to be entered into by SunTrust.
May 21, 2008 (PDF)
Letter to David R. Sahr approving the notice by Fortis S.A./N.V., Fortis N.V., Fortis Brussels S.A./N.V., and Fortis Bank S.A./N.V., all of Brussels, Belgium, to enter into physically settled tolling agreements with power plant owners in the United States.
April 10, 2008 (PDF)
Letter to John Shrewsberry approving the notice by Wells Fargo & Company, San Francisco, California, to engage on a limited basis in physical commodity trading activities.
January 8, 2008 (PDF)
Letter to a bank, clarifying that it could underwrite debt protection services for its customers and continue to qualify for the "credit card bank exemption" from the definition of bank in section 2(c)(2)(F) of the Bank Holding Company Act of 1956.