Legal Interpretations
Federal Reserve Act - 2001 Letters
November 21, 2001
Letter to Mr. Steven J. Eisen, providing the opinion that a loan from a bank to its affiliate that is fully secured by Guaranteed Interest Certificates (GICs) that are guaranteed by the SBA is exempt from the quantitative limits imposed by section 23A of the Federal Reserve Act, 12 USC 361c.
October 31, 2001
To J.P. Morgan Chase & Co., granting an exemption from section 23A of the Federal Reserve Act (12 USC 371c) for certain indemnities made by The Chase Manhattan Bank on behalf of, and certain extensions of credit made by the bank to, J.P. Morgan Securities Inc. (an affiliate of the bank), in connection with the bank’s securities lending program.
August 28, 2001
Letter to Citigroup Inc., New York, New York, granting an exemption from the quantitative limits of section 23A of the Federal Reserve Act, 12 USC 371c, in order that various subsidiary banks of Citigroup may acquire assets of Associates First Capital Corporation, Irving, Texas, an affiliate of the banks.
August 10, 2001
To Iberville Bank, opining that the attribution rule of section 23A of the Federal Reserve Act (12 U.S.C. 371c) would apply to loans by the bank to unaffiliated customers who use the loan proceeds to purchase real estate developed and sold as principal by an affiliate of the bank.
January 8, 2001
To Wells Fargo Bank, granting an exemption from section 23A of the Federal Reserve Act (12 USC 371c), in order that Wells Fargo & Company may contribute all the shares of a nonbank subsidiary, Servus Financial Corporation, to Wells Fargo Bank South Dakota, N.A., as part of a corporate restructuring.