Legal Interpretations
Bank Holding Companies/Savings and Loan Holding Companies/Change in Control - 2024 Letters
October 22, 2024 (PDF)
Letter to Brent McIntosh, Esq., granting a request by Citigroup Inc., 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.
October 22, 2024 (PDF)
Letter to William L. Kuhn IV, Esq., granting a request by HSBC North America Holdings Inc., New York, New York, to treat an issuance of credit-linked notes as a synthetic securitization because it is similar to and at least as effective as transactions commonly used for mitigating risk that the Board recognizes in its capital rule.
August 26, 2024 (PDF)
Letter to Alistair Webster granting a request by JPMorgan Chase & Co., 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.
August 23, 2024 (PDF)
Letter to Lee G. Lester, Esq., opining that no regulatory purpose would be served by requiring a filing under section 3 of the Bank Holding Company Act for Skyline Bankshares, Inc., Floyd, Virginia, a bank holding company, to acquire Johnson County Bank, Mountain City, Tennessee, a state nonmember bank.
June 20, 2024 (PDF)
Letter granting the requests by Bank of America 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.
June 20, 2024 (PDF)
Letter 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.
June 5, 2024 (PDF)
Letter to Michael Petrie granting a request by Merchants Bancorp, Carmel, Indiana, 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.
May 2, 2024 (PDF)
Letter to Matthew G. Bisanz, Esq., granting requests by Ally Financial Inc., Detroit, Michigan, and Ally Bank, Sandy, Utah, 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.
March 12, 2024 (PDF)
Letter to Stuart M. Litwin, Esq., granting a request by Truist Financial Corporation, Charlotte, North Carolina, 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.
March 09, 2024 (PDF)
Letter to Brian D. Christiansen, Esq., granting a request by New York Community Bancorp, Inc., Hicksville, New York, for a general exemption pursuant to the Depository Institution Management Interlocks Act and the Board’s Regulation L to permit Mr. Milton Berlinski to become a director of New York Community Bancorp, Inc. while at the same time serving as a director of EverBank Financial Corp and of EverBank, National Association, both of Jacksonville, Florida.