Bank Holding Company/Change in Control
2005 Letters
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October 31, 2005 (315 KB PDF)
- Letter to Mark Welshimer in response to an inquiry on behalf of Wachovia Corporation regarding the appropriate risk-based capital treatment of Wachovia�s equity investment in a consolidated financial guarantee reinsurance subsidiary, BluePoint Re Limited. The letter permits Wachovia to deconsolidate BluePoint for purposes of the Board�s bank holding company capital adequacy guidelines so long as Wachovia deducts its equity investment in BluePoint 50 percent from tier 1 capital and 50 percent from tier 2 capital.
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August 24, 2005 (938 KB PDF)
- Letter to a BHC stating that Board staff would not recommend that the Board (i) find that certain preferred shareholders would, individually or collectively, exercise a controlling influence over the management or policies of a majority-owned subsidiary of the BHC for purposes of the Bank Holding Company Act; or (ii) count the investment by the preferred shareholders in the majority-owned subsidiary of the BHC toward the investment limit of the investors for member bank investments in Edge and Agreement corporations under the Federal Reserve Act.
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July 14, 2005 (48 KB PDF)
- Letter to a BHC approving the BHC's proposed risk-based capital ("RBC") treatment for a synthetic securitization of margin loans proposed by the BHC that is intended to reduce the RBC requirements assessed against margin loans maintained on the BHC's balance sheet.
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February 18, 2005
- To Sherman Financial Group LLC clarifying that its acquisition of control of First National Bank of Marin, Las Vegas, Nevada, would be an acquisition of a bank that qualified for the "credit card bank exemption" from the definition of bank in section 2(c)(2)(F) of the Bank Holding Company Act of 1956.
Legal interpretations
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