Legal Interpretations
Bank Holding Companies/Savings and Loan Holding Companies/Change in Control - 2023 Letters
December 12, 2023 (PDF)
Letter to Juan Carlos Alvarez de Soto granting a request by Santander Holdings USA, Inc., Boston, Massachusetts, to treat certain issuances of credit-linked notes, and substantially identical credit-linked-note transactions, as synthetic securitizations because they are similar to and at least as effective as transactions commonly used for mitigating risk that the Board recognizes in its capital rule.
December 6, 2023 (PDF)
Letter to Matthew G. Bisanz, Esq., granting a request by Huntington Bancshares Incorporated, Columbus, Ohio, to treat a proposed issuance of credit-linked notes, and substantially identical credit-linked-note transactions, as synthetic securitizations because they are similar to and at least as effective as transactions commonly used for mitigating risk that the Board recognizes in its capital rule.
November 16, 2023 (PDF)
Letter to Matthew G. Bisanz, Esq., granting a request by U.S. Bancorp, Minneapolis, Minnesota, to treat a proposed issuance of credit-linked notes, and substantially identical credit-linked-note transactions, as synthetic securitizations because they are similar to and at least as effective as transactions commonly used for mitigating risk that the Board recognizes in its capital rule.
October 18, 2023 (PDF)
Letter to Santander Holdings 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.
October 16, 2023 (PDF)
Letter to Spencer A. Sloan, Esq., granting a request by U.S. Bancorp, Minneapolis, Minnesota, for relief from commitments made to the Board in connection with the acquisition of MUFG Union Bank, National Association, San Francisco, California.
September 29, 2023 (PDF)
Letter to Luigi L. De Ghenghi, Esq., granting a request by Morgan Stanley, New York, New York, to treat an issuance of credit-linked notes, and substantially identical credit-linked-note transactions, as synthetic securitizations because they are similar to and at least as effective as transactions commonly used for mitigating risk that the Board recognizes in its capital rule.
July 5, 2023 (PDF)
Letter to Agata S. Troy, Esq., opining that no regulatory purpose would be served by requiring a filing under section 3 of the Bank Holding Company Act for First Bank, Hamilton, New Jersey, a stand-alone state nonmember bank, to acquire Malvern Bancorp, Inc., a bank holding company, and its wholly owned bank subsidiary, Malvern Bank NA, both of Paoli, Pennsylvania.
April 21, 2023 (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.
April 14, 2023 (PDF)
Letter to Luigi L. De Ghenghi, Esq. granting approval of the notice under section 163(b) of the Dodd-Frank Wall Street Reform and Consumer Protection Act by UBS Group AG, Zurich, Switzerland, to acquire all of the shares of Credit Suisse Holdings (USA), Inc., New York, New York.
February 1, 2023 (PDF)
Letter to DWS USA 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.
February 1, 2023 (PDF)
Letter to Santander Holdings 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.
February 1, 2023 (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.
January 26, 2023 (PDF)
Letter to Scott A. Coleman, Esq., granting a request by Midcountry Acquisition Corp., Minneapolis, Minnesota, for a general exemption pursuant to the Depository Institution Management Interlocks Act and the Board's Regulation L to allow Mr. Brian Short to continue to serve as a director of Midcountry Acquisition Corp. while also serving as a management official of 215 Holding Co., Minneapolis, Minnesota, and certain affiliated entities.