Legal Interpretations
Bank Holding Companies/Savings and Loan Holding Companies/Change in Control - 2018 Letters
December 31, 2018 (PDF)
Letter to Gabriel D. Rosenberg, Esq., granting the requests by The Bank of New York Mellon Corporation, New York, New York, and State Street Corporation, Boston, Massachusetts, for an extension of time to comply with the clean holding company provisions of the Board’s total loss-absorbing capacity rule with respect to underwriting agreements, fully-paid structured share repurchase agreements, and employee and director stock options..
December 31, 2018 (PDF)
Letter to Randall D. Guynn, Esq., granting the requests by Bank of American Corporation, Charlotte, North Carolina, Wells Fargo & Company, San Francisco, California, and Citigroup Inc., The Goldman Sachs Group, Inc., JPMorgan Chase & Co., and Morgan Stanley, all of New York, New York, for an extension of time to comply with the clean holding company provisions of the Board's total loss-absorbing capacity rule with respect to underwriting agreements, fully-paid structured share repurchase agreements, and employee and director stock options.
December 26, 2018 (PDF)
Letter to Amanda K. Allexon, Esq., granting a request by Bank of Hawaii Corporation and Bank of Hawaii, both of Honolulu, Hawaii, for a general exemption pursuant to the Depository Institution Management Interlocks Act and the Board’s Regulation L to allow Mr. John C. Erickson to serve as a member of the boards of directors of each of Bank of Hawaii Corporation and Bank of Hawaii, while at the same time serving as a member of the boards of directors of each of Luther Burbank Corporation and Luther Burbank Savings, both of Santa Rosa, California.
December 14, 2018 (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.
December 13, 2018 (PDF)
Letter to Barclays US, LLC communicating the Board's approval under Regulation YY of a contractual provision that must be included in certain debt issued by U.S. intermediate holding companies of foreign GSIBs, on the terms explained in that letter.
December 13, 2018 (PDF)
Letter to BNP Paribas USA, Inc. communicating the Board's approval under Regulation YY of a contractual provision that must be included in certain debt issued by U.S. intermediate holding companies of foreign GSIBs, on the terms explained in that letter.
December 13, 2018 (PDF)
Letter to Credit Suisse Holdings U.S.A. communicating the Board's approval under Regulation YY of a contractual provision that must be included in certain debt issued by U.S. intermediate holding companies of foreign GSIBs, on the terms explained in that letter.
December 13, 2018 (PDF)
Letter to DB USA Corporation in relation to that entity and to DWS USA Corporation communicating the Board's approval under Regulation YY of contractual provisions that must be included in certain debt issued by U.S. intermediate holding companies of foreign GSIBs, on the terms explained in that letter.
December 13, 2018 (PDF)
Letter to HSBC North America Holdings, Inc. communicating the Board's approval under Regulation YY of a contractual provision that must be included in certain debt issued by U.S. intermediate holding companies of foreign GSIBs, on the terms explained in that letter.
December 13, 2018 (PDF)
Letter to MUFG Americas Holdings Corporation communicating the Board's approval under Regulation YY of a contractual provision that must be included in certain debt issued by U.S. intermediate holding companies of foreign GSIBs, on the terms explained in that letter.
December 13, 2018 (PDF)
Letter to UBS Americas Holding, LLC communicating the Board's approval under Regulation YY of a contractual provision that must be included in certain debt issued by U.S. intermediate holding companies of foreign GSIBs, on the terms explained in that letter.
December 7, 2018 (PDF)
Letter to Mr. John Eggemeyer granting a request by Capital Creek Capital and certain of its subsidiaries and affiliates for relief from commitments made to the Board in connection with their investment in shares of Trinity Capital Corporation, Los Alamos, New Mexico.
December 3, 2018 (PDF)
Letter to Mr. Joseph Hooley, granting a request by State Street Corporation for a one- year extension of time to comply with the requirement to hold eligible long-term debt that is no less than 4.5 percent of the firm's total leverage exposure under the Board’s Regulation YY.
November 16, 2018 (PDF)
Letter to Joel Mathiesen granting his request pursuant to section 19 of the Federal Deposit Insurance Act to remain an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
November 16, 2018 (PDF)
Letter to Ms. April Gilmore 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.
November 6, 2018
Letter to Steven J. Eisen, Esq., approving the notice on behalf of Mr. Gaylon M. Lawrence, Jr., Memphis, Tennessee, to acquire up to 15 percent of the voting shares of CapStar Financial Holdings, Inc., Nashville, Tennessee.
October 17, 2018 (PDF)
Letter to Mr. Neal Wilson granting a request by EJF Capital LLC, Arlington, Virginia, and affiliated entities for relief from commitments made to the Board in connection with the acquisition of preferred shares in HomeBancorp, Inc., Tampa, Florida.
October 17, 2018 (PDF)
Letter to Diana E. McCarthy, Esq., granting a request by Northern Funds and Northern Institutional Funds for a general exemption pursuant to the Depository Institution Management Interlocks Act and the Board's Regulation L to allow Ms. Ingrid LaMae Allen de Jongh to become a trustee on the boards of trustees of Northern Funds and Northern Institutional Funds, while at the same time serving as a director of Bank Leumi USA, New York, New York
September 26, 2018 (PDF)
Letter to Jeffrey A. Tisdale, Esq. granting relief to KEDAP S.A. de C.V., Mexico City, Mexico, and Enrique Rafael Schon Gritzewsky from certain commitments made to the Board in connection with the application by KEDAP S.A. de C.V. to become a bank holding company.
September 25, 2018
Letter to Ms. Jill Jensen granting her request pursuant to section 19 of the Federal Deposit Insurance Act to remain an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
September 20, 2018 (PDF)
Letter to Mr. Malik Cooper 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 24, 2018 (PDF)
Letter to Mr. Neal Wilson granting a request EJF Capital LLC, Arlington, Virginia, and affiliated entities for relief from commitments made to the Board in connection with the acquisition of preferred shares that Reliance Bancshares, Inc., Des Peres, Missouri, had issued to the Department of the Treasury.
August 24, 2018 (PDF)
Letter to Ms. Tahmineh Maloney, granting a request by E*Trade Financial Corporation for a two-year extension of time to comply with the CEO attestation requirement in Appendix B of the Board’s Regulation VV.
August 9, 2018 (PDF)
Letter to Ms. Danielle Getkin granting the request by Old Point Financial Corporation, Hampton, Virginia, for an extension of time until December 31, 2018, to begin the filing the FR Y-9C and FR Y-9LP financial reports.
August 9, 2018 (PDF)
Letter to Mr. Thomas DeRobertis granting the request by CNB Bank Shares, Inc., Carlinville, Illinois, for an extension of time until December 31, 2018, to begin the filing the FR Y-9C and FR Y-9LP financial reports.
August 9, 2018 (PDF)
Letter to Ms. Linda Andrews granting the request by CB Financial Services, Inc., Carmichaels, Pennsylvania, for an extension of time until December 31, 2018, to begin filing the FR Y-9C and FR Y-9LP financial reports.
August 7, 2018 (PDF)
Letter to Mr. Ronald DeMyers granting his request pursuant to section 19 of the Federal Deposit Insurance Act to remain an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
August 6, 2018 (PDF)
Letter to Mr. Ra’Shaad Hampton, 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 6, 2018 (PDF)
Letter to Thomas C. Baxter, Esq. advising that staff would not recommend that the Board find Barclays Bank PLC and Barclays PLC, both of London, England, to control Barclays Africa Group Limited, Johannesburg, South Africa, under the Bank Holding Company Act of 1956, if the transactions described in the letter are conducted according to the terms and conditions described in the letter and related correspondence.
May 30, 2018 (PDF)
Letter to Mr. Eric Joon granting a request by Hildene Capital Management, LLC and related entities for relief from commitments made to the Board in connection with the acquisition of preferred shares that RCB Financial Corporation, Rome, Georgia, had issued to the Department of the Treasury.
May 30, 2018 (PDF)
Letter to Mr. Eric Joon granting a request by Hildene Capital Management, LLC and related entities for relief from commitments made to the Board in connection with the acquisition of preferred shares that Georgia Primary Bank, Georgia, Atlanta, had issued to the Department of the Treasury.
May 30, 2018 (PDF)
Letter to Mr. Eric Joon granting a request by Hildene Capital Management, LLC and related entities for relief from commitments made to the Board in connection with the acquisition of preferred shares that Southcrest Financial Group, Inc., Atlanta, Georgia, had issued to the Department of the Treasury.
May 18, 2018 (PDF)
Letter to Ms. Sheryl Bollinger granting a request by AMG National Corp. for relief from commitments made to the Board in connection with AMG’s investment in shares of Qwinix Technologies, Inc.
May 17, 2018 (PDF)
Letter to Joseph P. Vitale, Esq. and Richard K. Kim, Esq., advising that staff would not recommend that the Board find Endicott SPV I, L.P. and MSD BLUSA Investments, L.L.C. to control Bank Leumi Le-Israel Corporation, New York, New York, under the Bank Holding Company Act of 1956, as amended, if the transactions described in the letter are conducted according to the terms and conditions described in the letter and related correspondence.
April 5, 2018 (PDF)
Letter to Donald S. Waack, Esq. advising that American Century Companies, Inc. and its 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.
March 20, 2018 (PDF)
Letter to Gary A. Cotogno, Esq., granting the request by Mr. Marc A. Cheramie pursuant to section 19 of the Federal Deposit Insurance Act to retain beneficial ownership of shares of SBT Bancshares, Inc., Golden Meadow, Louisiana.
March 7, 2018 (PDF)
Letter to Mr. Paul Stevelman granting relief to Royal Bank of Scotland Group plc, Edinburgh, Scotland, for relief from certain commitments made to the Board.
March 7, 2018 (PDF)
Letter to Jeremy E. Hill, Esq., granting a request by First Merchants Corporation for a general exemption pursuant to the Depository Institution Management Interlocks Act and the Board's Regulation L to allow Ms. Jean L. Wojtowicz to remain a director of First Merchants and its subsidiary, First Merchants Bank, both of Muncie, Indiana, while at the same time serving as a director of First Internet Bancorp and its subsidiary, First Internet Bank of Indiana, both of Fishers, Indiana.
March 6, 2018 (PDF)
Letter to Mr. Jacob Denney 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.
January 29, 2018 (PDF)
Letter to Mr. James W. Morrissey, opining that no regulatory purpose would be served by requiring a filing under section 3 of the Bank Holding Company Act, as amended, for Byline Bancorp, Inc., Chicago, Illinois, to acquire First Evanston Bancorp, Inc. and thereby indirectly acquire First Bank & Trust, both of Evanston, Illinois.
January 18, 2018 (PDF)
Letter to Mr. Francisco Oliveira granting relief to BNP Paribas, Paris, France, from certain commitments made to the Board in connection with notices filed under section 4 of the Bank Holding Company Act of 1956 to engage in activities that are complementary to a financial activity.
January 8, 2018 (PDF)
Letter to Ms. Kathleen Juhase granting a request by JPMorgan Chase & Co. for relief from commitments made to the Board in connection with JPMC's investment in shares of WKI Holding Company Inc.
January 3, 2018 (PDF)
Letter to Ms. Cynthia Duran, 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.
January 3, 2018 (PDF)
Letter to Mr. Rickey Washington, 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.