Legal Interpretations
Bank Holding Companies/Savings and Loan Holding Companies/Change in Control - 2019 Letters
December 26, 2019 (PDF)
Letter to Rebecca J. Simmons, Esq., granting a request by The Bank of New York Mellon Corporation, New York, New York, for an extension of time until July 1, 2020, to conform certain custody services contracts to certain requirements of the Board's QFC stay rule.
December 26, 2019 (PDF)
Letter to Rebecca J. Simmons, Esq., granting a request by Citigroup Inc., New York, New York, for an extension of time until July 1, 2020, to conform certain custody services contracts to certain requirements of the Board's QFC stay rule.
December 26, 2019 (PDF)
Letter to Rebecca J. Simmons, Esq., granting a request by Bank of America Corporation, Charlotte, North Carolina, for an extension of time until July 1, 2020, to conform certain custody services contracts to certain requirements of the Board's QFC stay rule.
December 26, 2019 (PDF)
Letter to Rebecca J. Simmons, Esq., granting a request by JPMorgan Chase & Co., New York, New York, for an extension of time until July 1, 2020, to conform certain custody services contracts to certain requirements of the Board's QFC stay rule.
December 26, 2019 (PDF)
Letter to Rebecca J. Simmons, Esq., granting a request by State Street Corporation, Boston, Massachusetts, for an extension of time until July 1, 2020, to conform certain custody services contracts to certain requirements of the Board's QFC stay rule.
December 26, 2019 (PDF)
Letter to Gabriel Rosenberg, Esq., granting a request by Wells Fargo & Company, San Francisco, California, for an extension of time until July 1, 2020, to conform certain non-U.S., non-linked contracts to certain requirements of the Board's QFC stay rule.
December 26, 2019 (PDF)
Letter to Gabriel Rosenberg, Esq., granting a request by Morgan Stanley, New York, New York, for an extension of time until July 1, 2020, to conform certain non-U.S., non-linked contracts to certain requirements of the Board's QFC stay rule.
December 26, 2019 (PDF)
Letter to Gabriel Rosenberg, Esq., granting a request by Citigroup Inc., New York, New York, for an extension of time until July 1, 2020, to conform certain non-U.S., non-linked contracts to certain requirements of the Board's QFC stay rule.
December 26, 2019 (PDF)
Letter to Gabriel Rosenberg, Esq., granting a request by JPMorgan Chase & Co., New York, New York, for an extension of time until July 1, 2020, to conform certain non-U.S., non-linked contracts to certain requirements of the Board's QFC stay rule.
December 26, 2019 (PDF)
Letter to Gabriel Rosenberg, Esq., granting a request by Bank of America Corporation, Charlotte, North Carolina, for an extension of time until July 1, 2020, to conform certain non-U.S., non-linked contracts to certain requirements of the Board's QFC stay rule.
December 29, 2019 (PDF)
Letter to Gabriel Rosenberg, Esq., granting a request by The Goldman Sachs Group, Inc., New York, New York, for an extension of time until July 1, 2020, to conform certain non-U.S., non-linked contracts to certain requirements of the Board's QFC stay rule.
December 13, 2019 (PDF)
Letter granting the requests by The Bank of New York Mellon Corporation, New York, New York, and State Street Corporation, Boston, Massachusetts, for an extension of time to comply with the clean holding company provisions of the Board’s total loss-absorbing capacity rule with respect to underwriting agreements, fully-paid structured share repurchase agreements, and employee and director stock options.
December 13, 2019 (PDF)
Letter granting the requests by Bank of American Corporation, Charlotte, North Carolina, Wells Fargo & Company, San Francisco, California, and Citigroup Inc., The Goldman Sachs Group, Inc., JPMorgan Chase & Co., and Morgan Stanley, all of New York, New York, for an extension of time to comply with the clean holding company provisions of the Board's total loss-absorbing capacity rule with respect to underwriting agreements, fully-paid structured share repurchase agreements, and employee and director stock options.
November 26, 2019 (PDF)
Letter to Anne E. Robinson advising that The Vanguard Group, Inc. and affiliated entities collectively may acquire up to 25 percent (for purposes of the Bank Holding Company Act or the Home Owners’ Loan Act), and up to 15 percent (for purposes of the Change in Bank Control Act) of any class of voting securities of a bank holding company, bank, savings and loan holding company, or savings association without being deemed to have acquired control of that institution, when the acquisition complies with certain conditions.
July 31, 2019 (PDF)
Letter to Kieran J. Fallon, Esq., granting a request by The PNC Financial Services Group, Inc., Pittsburgh, Pennsylvania, for a partial exemption from the definition of “credit exposure” for purposes of section 165(e) of the Dodd-Frank Act and the Board’s single-counterparty credit limits rule with respect to its investment in BlackRock, Inc., New York, New York.
June 28, 2019 (PDF)
Letter to Rebecca J. Simmons, Esq., granting a request by State Street Corporation, Boston, Massachusetts, for an extension of time to conform certain custody services contracts to certain requirements of the Board's QFC stay rule.
June 28, 2019 (PDF)
Letter to Rebecca J. Simmons, Esq., granting a request by The Bank of New York Mellon Corporation, New York, New York, for an extension to conform certain custody services contracts to certain requirements of the Board's QFC stay rule.
June 28, 2019 (PDF)
Letter to Rebecca J. Simmons, Esq., granting a request by Citigroup Inc., New York, New York, for an extension of time to conform certain custody services contracts to certain requirements of the Board's QFC stay rule.
June 28, 2019 (PDF)
Letter to Rebecca J. Simmons, Esq., granting a request by JPMorgan Chase & Co., New York, New York, for an extension of time to conform certain custody services contracts to certain requirements of the Board's QFC stay rule.
June 28, 2019 (PDF)
Letter to Gabriel Rosenberg, Esq., granting a request by Morgan Stanley, New York, New York, for an extension of time to conform certain non-U.S., non-linked contracts to certain requirements of the Board's QFC stay rule.
June 28, 2019 (PDF)
Letter to Gabriel Rosenberg, Esq., granting a request by Wells Fargo & Company, San Francisco, California, for an extension of time to conform certain non-U.S., non-linked contracts to certain requirements of the Board's QFC stay rule.
June 28, 2019 (PDF)
Letter to Gabriel Rosenberg, Esq., granting a request by Bank of America Corporation, Charlotte, North Carolina, for an extension of time to conform certain non-U.S., non-linked contracts to certain requirements of the Board's QFC stay rule.
June 28, 2019 (PDF)
Letter to Gabriel Rosenberg, Esq., granting a request by The Goldman Sachs Group, Inc., New York, New York, for an extension of time to conform certain non-U.S., non-linked contracts to certain requirements of the Board's QFC stay rule.
June 28, 2019 (PDF)
Letter to Gabriel Rosenberg, Esq., granting a request by Citigroup Inc., New York, New York, for an extension of time to conform certain non-U.S., non-linked contracts to certain requirements of the Board's QFC stay rule.
June 28, 2019 (PDF)
Letter to Gabriel Rosenberg, Esq., granting a request by JPMorgan Chase & Co., New York, New York, for an extension of time to conform certain non-U.S., non-linked contracts to certain requirements of the Board's QFC stay rule.
April 12, 2019 (PDF)
Letter to Luigi De Ghenghi, Esq., granting a request by Ameriprise Financial, Inc., Minneapolis, Minnesota, for a two-year extension of time to bring its activities and investments into compliance with the requirements of the Volcker Rule.
April 8, 2019 (PDF)
Letter to Nicholas Stager granting his request pursuant to section 19 of the Federal Deposit Insurance Act to remain an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
March 29, 2019 (PDF)
Letter to Ronald Murphy granting his request pursuant to section 19 of the Federal Deposit Insurance Act to remain an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
March 26, 2019 (PDF)
Letter to Mr. Maurice Coleman II, granting his request pursuant to section 19 of the Federal Deposit Insurance Act to become an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
March 13, 2019 (PDF)
Letter to Mr. Scott Freidenrich, granting a request by The Bank of New York Mellon Corporation, New York, New York, for a one-year extension of time to comply with the requirement to hold eligible long-term debt that is no less than 4.5 percent of the firm's total leverage exposure under the Board's Regulation YY.
February 26, 2019 (PDF)
Letter to Amanda M. Allexon, Esq. granting a request by Sageview Capital Partners LP and certain of its related entities and affiliates, for relief from commitments made to the Board in connection with their interests in shares of Cadence Bancorporation.
February 12, 2019 (PDF)
Letter to Thomas Corsi, Esq., advising that staff would not recommend that the Board find BNP Paribas, Paris, France, to control First Hawaiian, Inc., Honolulu, Hawaii, under the Bank Holding Company Act of 1956, as amended, if the transactions described in the letter are conducted according to the terms and conditions described in the letter and related correspondence.
February 1, 2019 (PDF)
Letter to Mr. Christopher Williams granting his request pursuant to section 19 of the Federal Deposit Insurance Act to become an institution-affiliated party of State Farm Mutual Automobile Insurance Company, Bloomington, Illinois.
January 7, 2019 (PDF)
Letter to Mr. John J. Bellini, granting the request by Auto Club Trust, FSB, Dearborn, Michigan, for an exception from the tying prohibitions in section 5(q) of the Home Owners' Loan Act of 1933, as amended (12 U.S.C. § 1464(q)).
January 4, 2019 (PDF)
Letter to Peter J. Morgan III, Esq., granting a request by The Charles Schwab Corporation for an extension of time to comply with the requirement to submit an implementation plan pursuant to section 217.121(b)(1) of the Board’s Regulation Q.