Legal Interpretations
Bank Holding Companies/Savings and Loan Holding Companies/Change in Control - 2017 Letters
December 20, 2017 (PDF)
Letter to Mark Chorazak, Esq., granting a modification to commitments made to the Board by Castle Creek Capital Partners V and certain affiliated entities in connection with the acquisition of shares in Guaranty Federal Bancshares, Inc., Springfield, Missouri.
October 27, 2017 (PDF)
Letter to Ms. Melody Scorzafava, granting her request pursuant to section 19 of the Federal Deposit Insurance Act to become an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
October 5, 2017 (PDF)
Letter to Ms. Teresa Thede, granting her request pursuant to section 19 of the Federal Deposit Insurance Act to become an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
September 7, 2017 (PDF)
Letter to Jason J. Cabral, Esq., granting a request by Mr. G. Kennedy Thompson for a general exemption pursuant to the Depository Institution Management Interlocks Act and the Board's Regulation L to allow Mr. Thompson to become a director of FirstSun Capital Bancorp, Denver, Colorado, while also serving as a director on the boards of Pinnacle Financial Partners and its subsidiary state nonmember bank, Pinnacle Bank, both of Nashville, Tennessee.
August 22, 2017 (PDF)
Letter to Kelton Johnson, Esq., granting the request pursuant to section 19 of the Federal Deposit Insurance Act to permit Mr. Derek Jones to become an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
August 3, 2017 (PDF)
Letter to Mr. Kyle Gonzalez, granting his request pursuant to section 19 of the Federal Deposit Insurance Act to become an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
August 3, 2017 (PDF)
Letter to Ms. Jessica West-Salazar, granting her request pursuant to section 19 of the Federal Deposit Insurance Act to become an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
August 3, 2017 (PDF)
Letter to Ms. Tanya Williams, granting her request pursuant to section 19 of the Federal Deposit Insurance Act to become an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
August 3, 2017 (PDF)
Letter to Ms. Jennifer Dawn Milteer Conn, granting her request pursuant to section 19 of the Federal Deposit Insurance Act to become an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
August 3, 2017 (PDF)
Letter to Mr. Jason Alexander Gibson, granting his request pursuant to section 19 of the Federal Deposit Insurance Act to become an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
July 28, 2017 (PDF)
Letter to Ms. Tracy Jackson, granting her request pursuant to section 19 of the Federal Deposit Insurance Act to become an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
July 28, 2017 (PDF)
Letter to Ms. LeVelle Kelley, granting her request pursuant to section 19 of the Federal Deposit Insurance Act to become an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
July 28, 2017 (PDF)
Letter to Ms. Angela Sowell, granting her request pursuant to section 19 of the Federal Deposit Insurance Act to become an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
July 28, 2017 (PDF)
Letter to Mr. Denis Velasquez, granting his request pursuant to section 19 of the Federal Deposit Insurance Act to become an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
July 28, 2017 (PDF)
Letter to Mr. Jerad Evans, granting his request pursuant to section 19 of the Federal Deposit Insurance Act to become an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
July 28, 2017 (PDF)
Letter to Mr. Timothy Vitense, granting his request pursuant to section 19 of the Federal Deposit Insurance Act to become an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
July 27, 2017 (PDF)
General Counsel opinion letter to Lynne M. McMahan, Esq., opining that no regulatory purpose would be served by requiring a filing under section 3 of the Bank Holding Company Act, as amended, for Horizon Bancorp, of Michigan City, Indiana, to merge with Lafayette Community Bancorp and thereby to acquire Lafayette Community Bank, both of Lafayette, Indiana.
July 3, 2017 (PDF)
General Counsel opinion letter to Robert L. Carothers, Jr., Esq., opining that no regulatory purpose would be served by requiring a filing under section 3 of the Bank Holding Company Act, as amended, for FirstBanc of Alabama, Inc., Talladega, Alabama, to acquire Swann Bancshares, Inc. and thereby indirectly acquire Bank of Wedowee, both of Wedowee, Alabama.
June 26, 2017 (PDF)
Letter to Mr. John Scannell granting relief to Hildene Capital Management LLC and affiliated entities from certain of the commitments made to the Board in connection with the acquisition of preferred shares in First Banks, Inc., Clayton, Missouri.
June 26, 2017 (PDF)
Letter to Mr. Craig A. Adoor granting relief to Trishield Special Situations Master Fund Ltd. and affiliated entities from certain of the commitments made to the Board in connection with the acquisition of preferred shares in First Banks, Inc., Clayton, Missouri.
June 26, 2017 (PDF)
Letter to Mr. Emanuel J. Friedman granting relief to EJF Capital LLC and affiliated entities from certain of the commitments made to the Board in connection with the acquisition of preferred shares in First Banks, Inc., Clayton, Missouri.
June 21, 2017 (PDF)
Letter to Ms. Joyce Leal, granting her request pursuant to section 19 of the Federal Deposit Insurance Act to become an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
June 21, 2017 (PDF)
Letter to Ms. Natalie Lozano, granting her request pursuant to section 19 of the Federal Deposit Insurance Act to become an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
June 21, 2017 (PDF)
Letter to Ms. Holly Ostlund, granting her request pursuant to section 19 of the Federal Deposit Insurance Act to become an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
June 21, 2017 (PDF)
Letter to Ms. Amanda Tapia, granting her request pursuant to section 19 of the Federal Deposit Insurance Act to become an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
June 21, 2017 (PDF)
Letter to Ms. Karen Moser, granting her request pursuant to section 19 of the Federal Deposit Insurance Act to become an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
June 21, 2017 (PDF)
Letter to Mr. Justin Case, granting his request pursuant to section 19 of the Federal Deposit Insurance Act to become an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
June 21, 2017 (PDF)
Letter to Ms. Sherry Tomlinson, granting her request pursuant to section 19 of the Federal Deposit Insurance Act to become an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
June 21, 2017 (PDF)
Letter granting a request pursuant to section 19 of the Federal Deposit Insurance Act to permit an individual to become an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
June 21, 2017 (PDF)
Letter granting a request pursuant to section 19 of the Federal Deposit Insurance Act to permit an individual to become an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
June 15, 2017 (PDF)
Letter to Satish M. Kini, Esq. advising that the Wellington Management Company LLP and affiliated entities collectively may acquire up to 15 percent of any class of voting securities of a bank holding company, bank, savings and loan holding company, or savings association without being deemed to have acquired control of that institution under the Bank Holding Company Act, the Home Owners' Loan Act, or the Change in Bank Control Act when the acquisition complies with certain conditions.
June 12, 2017 (PDF)
General Counsel opinion letter to Laura Biddle, Esq., opining that no regulatory purpose would be served by requiring a filing under section 3 of the Bank Holding Company Act, as amended, for Sussex Bancorp, of Rockaway, New Jersey, to acquire Community Bank of Bergen County, Maywood, New Jersey.
June 9, 2017 (PDF)
Letter to Jason J. Cabral, Esq., 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 become a director of Sunflower Reincorporation Sub, Inc., Salina, Kansas, while also serving as a director on the boards of BNC Bancorp, High Point, and its subsidiary state nonmember bank, Bank of North Carolina, Thomasville, both of North Carolina.
June 9, 2017 (PDF)
General Counsel opinion letter to Matthew T. Radetic, opining that no regulatory purpose would be served by requiring a filing under section 3 of the Bank Holding Company Act, as amended, for Amsterdam Bancshares, Inc., Amsterdam, Missouri, to acquire Bates County Bancshares, Inc., Rich Hill, Missouri.
May 18, 2017 (PDF)
General Counsel opinion letter to Michael White, Esq., opining that no regulatory purpose would be served by requiring a filing under section 3 of the Bank Holding Company Act, as amended, for PrimeSouth Bancshares, Inc. and Jones Bancshares, L.P., both of Waycross, Georgia, to acquire Atlantic National Bank, Brunswick, Georgia.
May 10, 2017 (PDF)
Letter to Michael K. Renetzky, Esq., approving the applications by Illinois Agricultural Association, Illinois Agricultural Holding Co., and COUNTRY Life Insurance Company, all of Bloomington, Illinois, to deregister as savings and loan holding companies.
May 9, 2017 (PDF)
Letter to Mr. Neal J. Wilson granting a request by EJF Capital LLC, Arlington, Virginia, and related entities for relief from commitments made to the Board in connection with the acquisition of preferred shares in The Baraboo Bancorporation, Inc., Baraboo, Wisconsin.
May 3, 2017 (PDF)
General Counsel opinion letter to Campbell White, Esq., opining that no regulatory purpose would be served by requiring a filing under section 3 of the Bank Holding Company Act, as amended, for Piper Holdings, Inc., Covington, Indiana, to acquire The Farmers State Bank, of Brookston, Indiana.
April 27, 2017 (PDF)
General Counsel opinion letter to Brian D. Christiansen opining that no regulatory purpose would be served by requiring a filing under section 3 of the Bank Holding Company Act, as amended, for HCBF Holding Company, Inc., Fort Pierce, Florida, to acquire Jefferson Bankshares, Inc., and thereby indirectly acquire Jefferson Bank of Florida, both of Oldsmar, Florida.
April 24, 2017 (PDF)
General Counsel opinion letter to Mark C. Dietzen, Esq., opining that no regulatory purpose would be served by requiring a filing under section 3 of the Bank Holding Company Act, as amended, for Royal Bancshares, Inc., Elroy, Wisconsin, to acquire State Bank of Cazenovia, Cazenovia, Wisconsin.
April 14, 2017 (PDF)
Letter to Patricia M. Schaubeck, Esq., granting a request by Sun Bancorp, Inc., Mount Laurel, New Jersey, for a general exemption pursuant to the Depository Institution Management Interlocks Act and the Board's Regulation L to allow Mr. James B. Lockhart III to become a director of Sun Bancorp while also serving as a director on the boards of Cascade Bancorp and its subsidiary state nonmember bank, Bank of the Cascades, both of Bend, Oregon.
April 13, 2017 (PDF)
General Counsel opinion letter to J. Daniel Patten opining that no regulatory purpose would be served by requiring a filing under section 3 of the Bank Holding Company Act, as amended, for Heartland Financial USA, Inc., Dubuque, Iowa, to acquire Citywide Banks of Colorado, Inc., Denver, Colorado, and thereby indirectly acquire Citywide Banks, Aurora, Colorado.
March 30, 2017 (PDF)
General Counsel opinion letter to Jennifer R. McCain, Esq., opining that no regulatory purpose would be served by requiring a filing under section 3 of the Bank Holding Company Act, as amended, for Progress Financial Corporation, Huntsville, Alabama, to acquire First Partners Financial, Inc., and thereby indirectly acquire First Partners Bank, both of Birmingham, Alabama.
March 27, 2017 (PDF)
General Counsel opinion letter to Burl Wells Spurlock, opining that no regulatory purpose would be served by requiring a filing under section 3 of the Bank Holding Company Act, as amended, for First Prestonsburg Bancshares, Inc., Prestonsburg, Kentucky, to acquire First Guaranty Bank, Martin, Kentucky.
March 24, 2017 (PDF)
General Counsel opinion letter to Craig Landrum, Esq., opining that no regulatory purpose would be served by requiring a filing under section 3 of the Bank Holding Company Act, as amended, for Renasant Corporation, Tupelo, Mississippi, to acquire Metropolitan BancGroup, Inc., of Ridgeland, Mississippi, and thereby indirectly acquire Metropolitan Bank, of Crystal Springs, Mississippi.
March 17, 2017 (PDF)
Letter to Mr. Thomas S. Riggs granting a request by The Goldman Sachs Group, Inc., New York, New York, and its subsidiaries and affiliates for relief from commitments made to the Board in connection with its ownership in SKBHC Holdings LLC and Atlantic Capital Bancshares, Inc.
March 17, 2017 (PDF)
General Counsel opinion letter to Edward Seksay, Esq., opining that no regulatory purpose would be served by requiring a filing under section 3 of the Bank Holding Company Act, as amended, for Independent Bank Corp., Hanover, Massachusetts, to acquire Island Bancorp., Inc. and thereby indirectly acquire The Edgartown National Bank, both of Edgartown, Massachusetts.
March 6, 2017 (PDF)
Letter to Edward J. Drenttel, Esq., granting a request pursuant to section 19 of the Federal Deposit Insurance Act to permit an individual to become an institution-affiliated party and own shares of Citizens Bank Group, Inc.
March 2, 2017 (PDF)
General Counsel opinion letter to Joseph Daly, Esq., opining that no regulatory purpose would be served by requiring a filing under section 3 of the Bank Holding Company Act, as amended, for First Guaranty Bancshares, Inc., Hammond, Louisiana, to acquire Premier Bancshares, Inc. and thereby indirectly acquire Synergy Bank, S.S.B., both of McKinney, Texas.
February 21, 2017 (PDF)
General Counsel opinion letter to Mr. Mark A. Wiebe, opining that no regulatory purpose would be served by requiring a filing under section 3 of the Bank Holding Company Act, as amended, for River Valley Bancorporation, Inc. to acquire Integrity First Bank, both of Wausau, Wisconsin.
February 15, 2017 (PDF)
To Kathleen M. Kearney, granting a request by John Deere Financial, f.s.b. (Thrift), Madison, Wisconsin, for an exception from the anti-tying prohibitions of section 5(q) of the Home Owners' Loan Act of 1933, as amended (12 U.S.C. § 1464(q)). The exception permits Thrift to continue to offer promotional financing terms through its credit card plans to consumers who purchase products manufactured by Thrift's affiliates.
February 8, 2017 (PDF)
General Counsel opinion letter to Stanley V. Ragalevsky, Esq., opining that no regulatory purpose would be served by requiring a filing under section 4 of the Bank Holding Company Act, as amended, for Salem Five Bancorp, Salem, Massachusetts, to acquire Georgetown Bancorp, Inc. and thereby indirectly acquire Georgetown Bank, both of Georgetown, Massachusetts.
January 26, 2017 (PDF)
General Counsel opinion letter to Lowell W. Harrison, Esq., opining that no regulatory purpose would be served by requiring a filing under section 3 of the Bank Holding Company Act, as amended, for AIM Bancshares, Inc., Levelland, Texas, to acquire High Plains Bancshares, Inc. and thereby indirectly acquire Muleshoe State Bank, both of Muleshoe, Texas.
January 25, 2017 (PDF)
Letter to Mark Chorazak, Esq., granting a request by Castle Creek Capital LLC, Rancho Santa Fe, California, for a general exemption pursuant to the Depository Institution Management Interlocks Act and the Board's Regulation L to allow Mr. John M. Eggemeyer to become a management official of The Bancorp, Inc., Wilmington, Delaware, while also serving as a management official of PacWest Bancorp, Beverly Hills, California, and Guaranty Bancorp, Denver, Colorado.
January 25, 2017 (PDF)
Letter to Michael Shumaker, Esq., granting a request pursuant to section 19 of the Federal Deposit Insurance Act to permit an individual to become an institution-affiliated party and own shares of Peach State Bancshares, Inc., Gainesville, Georgia.