Federal Reserve Act
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
- 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
- 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
- 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.