Legal Interpretations
Bank Holding Company/Change in Control - 2009 Letters
December 15, 2009 (PDF)
Letter to Andrew S. Baer, Esq., advising that Barclays PLC, London, United Kingdom, would not be deemed to control BlackRock, Inc., New York, New York, under the Bank Holding Company Act, as amended, if the transactions described in the letter are conducted according to certain conditions described in the letter and related correspondence.
November 18, 2009 (PDF)
Letter to Shaheen F. Dil granting an exemption under the Board's advanced capital adequacy framework for bank holding companies to permit The PNC Financial Services Group, Inc., Pittsburgh, Pennsylvania, to extend its first floor period start date by one year.
August 11, 2009 (PDF)
Letter to Jon Macey granting temporary relief from the Board's regulatory reporting requirements for bank holding companies to CIT Group Inc., New York, New York.
July 2, 2009 (PDF)
Letter to Andrew S. Baer approving the notice by Barclays PLC, London, England, to expand the scope of previously approved physical commodities trading activities; measure compliance with the quantitative limits on its physical commodity trading at the parent company level; enter into physically settled tolling agreements with power plant owners; and provide energy management services to power plant owners, all in the United States.
June 5, 2009 (PDF)
Letter to Paul E. Glotzer granting an exemption from the Board's risk-based capital guidelines for state member banks and bank holding companies (12 CFR Parts 208 and 225, Appendix A) to permit participants in ICE US Trust LLC ("ICE Trust"), New York, New York, to assign a 20 percent risk weight to claims on ICE Trust.
May 28, 2009 (PDF)
Letter to Paul E. Glotzer granting an extension of time to BNP Paribas, Paris, France, to divest of a merchant banking investment.
May 19, 2009 (PDF)
Letter to Christopher Greene granting temporary relief from the Board's regulatory reporting requirements for bank holding companies to Discover Financial Services, Riverwoods, Illinois.
April 20, 2009 (PDF)
Letter to Mark Lenczowski granting a request by JPMorgan Chase & Co., New York, New York, for relief from commitments made to the Board in connection with its notice to purchase and sell commodities in the spot market and to take and make delivery of physical commodities to settle commodity derivative transactions.
April 13, 2009 (PDF)
Letter to David J. DeBrunner granting temporary relief from the Board's regulatory reporting requirements for bank holding companies to GMAC LLC, Detroit, Michigan.
April 13, 2009 (PDF)
Letter to Denise Sawyer granting temporary relief from the Board's regulatory reporting requirements for bank holding companies to Bank of America Corporation, Charlotte, North Carolina.
April 10, 2009 (PDF)
Letter to Fred Gonfiantini granting an exemption from the Board’s risk-based capital guidelines for bank holding companies (12 CFR Part 225, App. A) to permit Morgan Stanley, New York, New York, to assign a 10 percent risk weight to its Regulation T margin loans.
April 10, 2009 (PDF)
Letter to Sarah Smith granting an exemption from the Board’s risk-based capital guidelines for bank holding companies (12 CFR Part 225, App. A) to permit The Goldman Sachs Group, Inc., New York, New York, to assign a 10 percent risk weight to its Regulation T margin loans.
March 30, 2009 (PDF)
Letter to Gregory A. Baer granting an exemption from the Board's risk-based capital guidelines for bank holding companies (12 CFR Part 225, App. A) to permit Bank of America Corporation, Charlotte, North Carolina, to include in tier 1 capital certain deferred tax assets acquired in connection with its purchase of Merrill Lynch & Company, Inc.
March 24, 2009 (PDF)
Letter to B. Robbins Kiessling, Esq., advising that General Motors Corporation would not control GMAC LLC, both of Detroit, Michigan, under the Bank Holding Company Act, as amended, if the actions described in the letter are taken in accordance with certain conditions described in the letter and related corresondence.
March 24, 2009 (PDF)
Letter to Daniel M. Rossner advising that (i) the Board has determined not to disapprove the notice under the Change in Bank Control Act by the Government of Singapore Investment Corporation Pte. Ltd. ("GIC") to acquire up to 19.9 percent of the voting shares of Citigroup, New York, New York, as part of a share exchange offer and (ii) GIC would not be deemed to control Citigroup or its subsidiary banks under the Bank Holding Company Act as a result of its participation in the share exchange offer.
March 24, 2009 (PDF)
Letter to Joseph P. Vitale, Esq., advising that Stephen A. Feinberg and the entities he controls or advises would not control GMAC LLC, Detroit, Michigan, under the Bank Holding Company Act, as amended, if the transactions described in the letter are consummated according to certain conditions described in the letter and related correspondence.
March 12, 2009 (PDF)
Letter to Sarah Smith granting modifications related to the Board's regulatory reporting requirements for bank holding companies and state member banks to The Goldman Sachs Group, Inc. and Goldman Sachs Bank USA, both of New York, New York.
February 20, 2009 (PDF)
Letter to Paul R. Ackerman granting an exemption from the Board's risk-based capital guidelines for bank holding companies (12 CFR Part 225, App. A) to permit Wells Fargo & Company, San Francisco, California, to include in tier 1 capital certain deferred tax assets acquired in connection with its purchase of Wachovia Corporation.
February 17, 2009 (PDF)
Letter to David J. DeBrunner granting temporary relief from the Board's regulatory reporting requirements for bank holding companies to GMAC LLC, Detroit, Michigan.
February 17, 2009 (PDF)
Letter to Jon Macey granting temporary relief from the Board's regulatory reporting requirements for bank holding companies to CIT Group Inc., New York, New York.
February 11, 2009 (PDF)
Letter to Stephen Linehan granting an exemption from the requirements of the Board's market risk rule for bank holding companies (12 CFR part 225, Appendix E) to Capital One Financial Corporation, McLean, Virginia.
February 5, 2009 (PDF)
Letter to Joan C. Amble granting temporary relief from and other modifications related to the Board's regulatory reporting requirements for bank holding companies to the American Express Company, New York, New York.
February 5, 2009 (PDF)
Letter to Gregory A. Baer granting temporary exemptions from application of certain aspects of the Board's market risk rule for bank holding companies (12 CFR part 225, Appendix E) to Bank of America Corporation, Charlotte, North Carolina, in connection with its purchase of Merrill Lynch & Co., Inc., New York, New York.
February 5, 2009 (PDF)
Letter to Colm Kelleher granting a temporary exemption from application of certain aspects of the Board's market risk rule for bank holding companies (12 CFR part 225, Appendix E) to Morgan Stanley, New York, New York.
February 5, 2009 (PDF)
Letter to Colm Kelleher granting temporary relief from and other modifications related to the Board's regulatory reporting requirements for bank holding companies to Morgan Stanley, New York, New York.
February 5, 2009 (PDF)
Letter to Sarah Smith granting temporary exemptions from application of certain aspects of the Board's market risk rules for state member banks and bank holding companies (12 CFR parts 208 and 225, Appendix E) to The Goldman Sachs Group, Inc. and Goldman Sachs Bank USA, both of New York, New York.
February 5, 2009 (PDF)
Letter to Sarah Smith granting temporary relief from and other modifications related to the Board's regulatory reporting requirements for bank holding companies and state member banks to The Goldman Sachs Group, Inc. and Goldman Sachs Bank USA, both of New York, New York.