Legal Interpretations
Bank Holding Companies/Savings and Loan Holding Companies/Change in Control - 2014 Letters
December 17, 2014 (PDF)
Letter to Thomas Riggs granting a request by Goldman Sachs Bank USA, New York, New York, for relief from a commitment made to the Board in connection with an exemption under section 23A of the Federal Reserve Act granted to GS Bank on April 22, 2009.
December 12, 2014 (PDF)
Letter to Mark B. Hillis, Esq., approving the notice on behalf of Mr. Andrew Love, individually and as part of a group acting in concert, to control Midland States Bancorp, Inc., Effingham, Illinois.
November 13, 2014 (PDF)
Letter to David W. Barton, Esq., approving the notice on behalf of Rick A. and Michele L. Tromble, Cheboygan, Michigan, to retain 10.74 percent of the voting shares of CNB Corporation, Cheboygan.
October 8, 2014 (PDF)
Letter to Brian D. Christiansen granting a request by WL Ross & Co. LLC, New York, New York, and related entities for relief from commitments made to the Board in connection with their investment in the Governor and Company of the Bank of Ireland, Dublin, Ireland.
August 11, 2014 (PDF)
Letter to Nathan L. Berger, Esq. granting a request made pursuant to 12 CFR 225.12(d)(2) by First Financial Bancorp ("First Financial"), Cincinnati, Ohio, that the Board not require the filing of a formal application under the Bank Holding Company Act in connection with First Financial's proposed acquisition of Guernsey Bancorp, Inc., Westerville, Ohio, and its wholly-owned subsidiary bank, The Guernsey Bank, Worthington, Ohio.
August 11, 2014 (PDF)
Letter to Mr. Seymour M. Jacobs granting the request by Jacobs Asset Management, LLC, New York, New York, for relief from commitments it made to the Board in connection with its acquisition of securities that were issued by Community West Bancshares, Goleta, California, to the Department of the Treasury as part of the Troubled Asset Relief Program's Capital Purchase Program.
July 22, 2014 (PDF)
Letter to Stephen T. Milligan granting a request by Aquiline Capital Partners LLC, New York, New York, for a general exemption pursuant to the Depository Institution Management Interlocks Act and the Board's Regulation L to allow Mr. G. Kennedy Thompson to continue to serve as a director on the boards of Strategic Growth Bank Incorporated and Strategic Growth Bancorp Incorporated, both of El Paso, Texas, while also serving as a director on the boards of BNC Bancorp, High Point, and Bank of North Carolina, Thomasville, both of North Carolina.
July 21, 2014 (PDF)
General Counsel opinion letter to Lawrence M.F. Spaccasi opining that no regulatory purpose would be served by requiring a filing under the Bank Holding Company Act of 1956, as amended, for Mascoma Mutual Financial Services Corporation, a federal mutual savings and loan holding company, to acquire Connecticut River Bancorp, Inc., Charlestown, New Hampshire, a bank holding company, its wholly-owned subsidiary national bank, Connecticut River Bank, Springfield, Vermont, and New Hampshire Trust Company, Keene, New Hampshire, a non-depository trust company in which Connecticut River Bank holds a 41.4 percent interest.
July 21, 2014 (PDF)
Letter to Julie Kunetka granting a request by Jay D. Bergman ("Notificant"), Joliet, Illinois, for an extension of time to fulfill certain commitments made by Notificant in connection with his notice filed pursuant to the Change in Bank Control Act of 1978 and the Board's Regulation Y, to acquire up to 94.65 percent of the shares of Community Holdings Corporation and thereby indirectly control FirstSecure Bank and Trust Co., both of Palos Hills, Illinois.
July 18, 2014 (PDF)
General Counsel opinion letter to Joseph P. Daly opining that no regulatory purpose would be served by requiring a filing under the Bank Holding Company Act of 1956, as amended, for AF Mutual Holding Company, a federal mutual savings and loan holding company, and its subsidiary, Alamogordo Financial Corporation, a federal savings and loan holding company, both of Alamogordo, New Mexico, to acquire Bank 1440, a state-chartered bank, Phoenix, Arizona.
July 17, 2014
Letters to Dino Verardo, Stuart Merzer, and Joseph Signorile granting requests by Sageview Capital (PDF), Greenwich, Connecticut, Paulson & Co. Inc. (PDF), New York, New York, and Kensico Capital Management (PDF), Greenwich, Connecticut, respectively, for relief from commitments made to the Board in connection with their investments in State Bank Financial Corporation, Atlanta, Georgia.
July 16, 2014
Letters to Emanuel J. Friedman granting requests by EJF Capital LLC, Arlington, Virginia, for relief from commitments it made to the Board in connection with its acquisition of securities that were issued by NewBridge Bancorp (PDF), Greensboro, North Carolina; Midtown Bank & Trust Company (PDF), Atlanta, Georgia; and United Community Banks, Inc. (PDF), Blairsville, Georgia, to the Department of the Treasury as part of the Troubled Asset Relief Program's Capital Purchase Program.
July 15, 2014 (PDF)
Letter to Jill E. York granting a request by MB Financial, Inc., Chicago, Illinois, for a general exemption pursuant to the Depository Institution Management Interlocks Act and the Board's Regulation L to allow Ms. Jennifer W. Steans to serve as a management official of MB Financial while also serving as a management official of USAmeriBancorp, Inc. and USAmeriBank, both of Clearwater, Florida.
June 25, 2014 (PDF)
Letter to Denise L. Skingle, Esq. granting a request by Nationwide Mutual Insurance Company, Nationwide Corporation, and Nationwide Financial Services, Inc., (collectively, "Nationwide") all of Columbus, Ohio, for an exemption pursuant to the Depository Institution Management Interlocks Act and the Board’s Regulation L to allow Mr. Suku Radia to serve as a management official of Nationwide while also serving as a management official of BTC Financial Corporation, MidAmerica Financial Corporation, and Bankers Trust Company, all of Des Moines, Iowa, and Bankers Trust Company, Cedar Rapids, Iowa.
May 2, 2014 (PDF)
Letter to Neal J. Wilson granting a request by EJF Capital LLC, Arlington, Virginia, for relief from commitments it made to the Board in connection with its acquisition of securities that were issued by Layton Park Financial Group, Inc., West Allis, Wisconsin, to the Department of the Treasury as part of the Troubled Asset Relief Program's Capital Purchase Program.
May 2, 2014 (PDF)
Letter to Jane N. Henderson granting a request by Virginia Community Capital, Inc. ("VCC") and its subsidiary depository organization, Community Capital Bank, both of Christiansburg, Virginia, for relief from one of several commitments made to the Board in connection with VCC's approval to become a bank holding company.
April 24, 2014 (PDF)
Letter to Edwin S. del Hierro approving the notice filed by Jay D. Bergman, Joliet, Illinois, to acquire up to 94.65 percent of Community Holdings Corporation, Palos Hills, Illinois.
April 17, 2014 (PDF)
Letter to Brian D. Christiansen, Esq., granting a request by BankUnited, Inc. and its subsidiary, BankUnited, National Association, both of Miami Lakes, Florida, for relief from commitments made to the Board by The Blackstone Group, WL Ross & Co. LLC and Invesco Ltd., and Centerbridge Partners, L.P., each of New York, New York, and The Carlyle Group, Washington, D.C., in connection with their investments in BankUnited, Inc. and BankUnited, National Association.
March 27, 2014 (PDF)
Letter to Robert D. Klingler granting a request by EJF Capital LLC, Arlington, Virginia, for relief from a commitment it made to the Board in connection with its acquisition of securities that were issued by Flagstar Bancorp, Inc., Troy, Michigan, to the Department of the Treasury as part of the Troubled Asset Relief Program's Capital Purchase Program.
March 13, 2014 (2.4 MB PDF)
Letters to Neal J. Wilson granting requests by EJF Capital LLC, Arlington, Virginia, for relief from commitments it made to the Board in connection with its acquisition of securities that were issued by Central Community Corporation, Temple, Texas; Corning Bancorp, Inc., Corning, Arkansas; and F&M Bancshares, Inc., Trezevant, Tennessee, to the Department of the Treasury as part of the Troubled Asset Relief Program's Capital Purchase Program.
January 13, 2014 (PDF)
Letter to Joel Alfonso, Esq., granting a request by Warburg Pincus Private Equity X, L.P., New York, New York, and related entities for relief from commitments made to the Board in connection with the acquisition of voting shares in Webster Financial Corporation, the parent company of Webster Bank, National Association, both of Waterbury, Connecticut.