Legal Interpretations
Federal Reserve Act - 2004 Letters
December 22, 2004
Letter to HSBC Bank USA, National Association, New Castle, Delaware, granting an exemption from the quantitative limits of section 23A of the Federal Reserve Act and Regulation W, 12 USC 371c and 12 CFR 223.43, in order that the bank may acquire certain assets from Household International Inc., Prospect Heights, Illinois.
July 7, 2004
Letter to GMAC Commercial Mortgage Company, Midvale, Utah, granting an exemption from the quantitative limits of section 23A of the Federal Reserve Act, 12 USC 371c, in order that the bank may acquire certain mortgage credits from GMAC Commercial Holding Corp., Horsham, Pennsylvania.
May 14, 2004
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 its subsidiary, Citicorp Trust Bank, fsb, Newark, Delaware, may acquire CitiFinancial Mortgage Company, Irving, Texas.
February 10, 2004
Letter to Merrill Lynch Bank USA, Salt Lake City, Utah, granting an exemption from the quantitative limits of section 23A of the Federal Reserve Act, 12 USC 371c, in order that the bank may acquire Merrill Lynch Private Finance, Inc., from Merrill Lynch & Co., Inc., New York, New York.
January 26, 2004
Letter to American Securitization Forum in response to an inquiry regarding the characterization under the Board's Regulation D (Reserve Requirements of Depository Institutions, 12 CFR Part 204) and Regulation Q (Prohibition Against Payment of Interest on Demand Deposits, 12 CFR Part 217) of certain liabilities of asset-backed commercial paper conduits sponsored by depository institutions following the issuance of Interpretation No. 46, "Consolidation of Variable Interest Entities" (FIN 46), by the Financial Accounting Standards Board. The letter expresses staff's opinion that such liabilities would not be "deposits" or otherwise reservable liabilities of the sponsoring depository institution for purposes of Regualtion D and also would not be "demand deposits" for purposes of Regulation Q.