Legal Interpretations
Federal Reserve Act - 1996 Letters
December 19, 1996
Letter to Depository Trust Company concerning the ability under the Glass-Steagall Act of DTC to purchase 50 percent membership interest in International Depository & Clearing LLC, a limited liability company that would be jointly owned with the National Securities Clearing Corporation.
December 6, 1996
Letter concerning the exemption in Regulation O (12 CFR 215.3(b)(5)(ii)) from the definition of "extension of credit" for indebtedness of $15,000 or less, arising from certain types of open-end credit plans. 12 USC 375a.
December 6, 1996
Letter concerning application of the overdraft provision of Regulation O (12 CFR 215.4(e)) to a bank's check processing procedures. 12 USC 375a.
November 14, 1996
To Mr. Michael Phenner confirming that reinsurance by a captive insurance subsidiary of corporate owned life insurance policies on the lives of the directors, officers or employees of the bank holding company, its bank and nonbank subsidiaries is a permissible servicing activity under BHCA 4(a)(2) and 4(c)(1) (12 USC 1843(a)(2) and (c)(1)(C)); and subject to certain restrictions, is not a covered transaction under FRA 23A, 12 USC 371c.
November 4, 1996
To Chase Manhattan Bank concerning the Glass-Steagall implications of a limited liability company engaged in data processing activities whose members will be a wholly-owned operating subsidiary and a software company.
November 1, 1996
To Electronic Data Systems concerning limitations under Regulation D (12 CFR 204) on payments from a savings account to a third party made pursuant to instructions given telephonically or through an ATM. 12 USC 461
September 4, 1996
To Electronic Data Systems regarding limitations under Regulation D (12 CFR 204) on the number of transfers and withdrawals from savings accounts. 12 U.S.C. 461
August 30, 1996
To Mr. Russell Dawn concerning the Regulation D (12 CFR 204) implications of a proposed new deposit product for corporate customers, consisting of a non-interest bearing demand deposit account, an interest bearing savings account, and a line of credit providing overdraft protections for the demand deposit account.
August 26, 1996
To American State Bank concerning its ability under FRA 23A (12 U.S.C. 371c) to extend credit to farmers who use the loan proceeds to produce crops on farmland that is leased from an affiliate of the bank.
July 11, 1996
To Mr. Shane Hansen concerning the Glass-Steagall implications of two proposals by Old Kent Bank: (a) to join a limited partnership formed by a group of financial institutions involved in the credit card business; and (b) to restructure its mortgage banking activities by transferring a mortgage banking subsidiary from the bank holding company to the bank. The subsidiary, Republic Mortgage Company, has interests in two joint ventures, a general partnership and a limited liability company that engage in originating residential mortgages.
July 11, 1996
To Mr. Michael Greenspan concerning the Glass-Steagall implications of a proposal by Comerica Bank to invest through a subsidiary in a limited liability company to provide credit card payment services to merchants.
July 3, 1996
To Mr. Mark Gillett concerning a proposal to use checks drawn by a savings bank to extend a line of credit to a customer, and whether they are reservable under Regulation D (12 CFR 204).
June 18, 1996
To Mr. Donald Toumey concerning the appropriate amount of Reserve Bank stock to be held under Regulation I (12 CFR 209.3) by a national bank after a restructuring of its assets. 12 U.S.C. 287
April 30, 1996
To a state member bank regarding the effect the aggregate limit in FRA 22(h) on extensions of credit by a bank to insiders could have on the bank's continued growth.
April 29, 1996
To Federal Reserve Bank of Cleveland regarding sweeps of certified and official checks into money market deposit accounts under Regulation D (12 CFR 204).
January 24, 1996
To Mr. Russell Dawn applying the restrictions of Regulation D (12 CFR 204) and Regulation Q (12 CFR 217) to a product consisting of a non-interest bearing demand deposit account, and interest bearing savings account, and a line of credit providing overdraft protection for the demand deposit.
January 17, 1996
To Bank One concerning reporting of loans subject to HMDA (12 CFR 203) that were purchased pursuant to conditions set by 12 CFR 250.250, interpreting FRA 23A.