Legal Interpretations
Federal Reserve Act - 2009 Letters
June 23, 2009 (PDF)
Letter to Brian Short granting an exemption from Section 23A of the Federal Reserve Act (12 U.S.C. 371c) and the Board's Regulation W (12 CFR Part 223) to allow First Farmers & Merchant State Bank of Grand Meadow, Grand Meadow, to acquire the bank's premises from its parent, 215 Holding Co., Minneapolis, both of Minnesota.
May 21, 2009 (PDF)
Letter to Richard K. Kim, Esq., Wachtell, Lipton, Rosen & Katz, granting exemptions from Section 23A of the Federal Reserve Act (12 U.S.C. 371c) and the Board's Regulation W (12 CFR Part 223) to allow Ally Bank, Midvale, Utah, to lend to consumers to enable them to purchase automobiles from unaffiliated dealers in the United States that obtain floorplan financing from Ally Bank or affiliates of Ally Bank and to provide floorplan financing to unaffiliated dealers to purchase automobiles from General Motors Corporation.
April 22, 2009 (PDF)
Letter to Michael Civitella (Goldman Sachs Bank USA), for exemptions from section 23A of the Federal Reserve Act and the Board's Regulation W and an exception from the anti-tying restrictions in section 106 of the Bank Holding Company Act of 1970 to allow Goldman Sachs Group Inc. to transfer certain assets to its subsidiary bank.
April 22, 2009 (PDF)
Letter to Paul E. Glotzer, Esq. (Morgan Stanley Bank, N.A.) for exemptions from section 23A of the Federal Reserve Act and the Board's Regulation W and an exception from the anti-tying restrictions in section 106 of the Bank Holding Company Act of 1970 to allow Morgan Stanley to transfer certain assets to its subsidiary bank.
April 13, 2009 (PDF)
Letter to William J. Sweet, Jr., Esq., Skadden, Arps, Slate, Meagher & Flom LLP, granting an exemption from Section 23A of the Federal Reserve Act (12 U.S.C. 371c) and the Board's Regulation W (12 CFR Part 223) for CIT Bank ("Bank"), Salt Lake City, Utah, to allow Bank to acquire all the shares of three affiliates.
April 3, 2009 (PDF)
Letter to Bradley K. Sabel, Esq., Shearman & Sterling LLP, determining that management interlocks between ICE US Trust LLC and unaffiliated depository organizations would not be prohibited by the Depository Institution Management Interlocks Act (12 U.S.C. 3201) or Regulation L (12 CFR 212).
March 31, 2009 (PDF)
Letter to Mark J. Welshimer, Esq., Sullivan & Cromwell LLP, granting an exemption from Section 23A of the Federal Reserve Act (12 U.S.C. 371c) and the Board's Regulation W (12 CFR Part 223) for ING Bank, fsb ("Bank"), Wilmington, Delaware, to allow Bank (i) to transfer to an affiliate an 80 percent participation interest in certain mortgage-backed securities and (ii) to receive from that affiliate an assignment of the affiliate's right to certain payments by the Dutch government.
January 30, 2009 (PDF)
Letter to William E. Stern, Esq., Goodwin Procter LLP, granting an exemption from section 23A of the Federal Reserve Act (12 U.S.C. 371c) and the Board's Regulation W (12 CFR Part 223) for Fifth Third Bank ("Bank"), Cincinnati, Ohio, to allow (i) an affiliate to hold and receive payments on variable rate demand notes (“VRDNs”) that are backed by a liquidity facility provided by Bank and (ii) Bank to purchase VRDNs from an affiliate.
January 14, 2009 (PDF)
Letter to John G. Holinka, granting an exemption from section 23A of the Federal Reserve Act (12 U.S.C. 371c) and the Board's Regulation W (12 CFR part 223) to permit HSBC Bank USA, National Association, McLean, Virginia, to purchase assets from an affiliate.
January 12, 2009 (PDF)
Letter to William S. Eckland, Sidley Austin LLP, granting an exemption from section 23A of the Federal Reserve Act (12 U.S.C. 371c) and the Board's Regulation W (12 CFR part 223) to permit GE Money Bank, Salt Lake City, Utah, to purchase assets from an affiliate.
January 9, 2009 (PDF)
Letter to Jennifer M. Dirkin, Esq., Northern Trust Corporation, granting an exemption from Section 23A of the Federal Reserve Act (12 U.S.C. 371c) and the Board's Regulation W (12 CFR Part 223) for The Northern Trust Company ("Bank"), Chicago, Illinois, to allow Bank to purchase auction-rate securities (“ARS”) from an affiliate.
January 9, 2009 (PDF)
Letter to Charles M. Horn, Esq., Mayer Brown LLP, granting an exemption from Section 23A of the Federal Reserve Act (12 U.S.C. 371c) and the Board's Regulation W (12 CFR Part 223) for Branch Banking and Trust Company ("Bank"), Winston-Salem, North Carolina, to allow (i) An affiliate to hold and receive payments on variable-rate demand notes ("VRDNs") and tender option bonds ("TOBs") that are backed by a liquidity facility provided by Bank and (ii) Bank to purchase VRDNs and TOBs from an affiliate.