Legal Interpretations
Bank Holding Companies/Savings and Loan Holding Companies/Change in Control - 2015 Letters
December 21, 2015 (PDF)
Letter to Andrew R. Gladin granting a request by BankCap Equity Fund, LLC, BankCap Partners GP, L.P., and BankCap Partners Opportunity Fund, L.P. and certain of their affiliates, all of Dallas, Texas, for relief from a commitment made to the Board in connection with BankCap Partners Opportunity Fund, L.P.'s acquisition of voting securities of Silvergate Capital Corporation, La Jolla, California.
December 18, 2015 (PDF)
Letter to Neal J. Wilson granting the request by EJF Capital LLC, Arlington, Virginia, for relief from commitments it made to the Board in connection with the acquisition of voting shares in Bank of the Carolinas Corporation, Mocksville, North Carolina, which was subsequently merged into Bank of the Ozarks, Inc., Little Rock, Arkansas.
December 17, 2015 (PDF)
Letter to Neal J. Wilson granting the request by EJF Capital LLC, Arlington, Virginia, for relief from commitments it made to the Board in connection with its acquisition of securities that were issued by AB&T Financial Corporation, Gastonia, North Carolina, to the Department of Treasury as part of the Troubled Asset Relief Program’s Capital Purchase Program.
November 16, 2015 (PDF)
Letter to Frank C. Bonaventure Jr., Esq., granting a request by SFSB, Inc., Bel Air, Maryland, a savings and loan holding company, for approval of its plan of dissolution pursuant to the Board's Regulation MM.
October 26, 2015 (PDF)
Letter to Mr. Thomas Riggs, granting a request by The Goldman Sachs Group, Inc., New York, New York, and related entities for relief from commitments made to the Board in connection with the acquisition of voting shares of Avenue Financial Holdings, Inc., the parent company of Avenue Bank, both of Nashville, Tennessee.
October 22, 2015 (PDF)
Letter to Scott A. Anenberg, Esq., that the elections filed by The Desjardins Group and the Fédération des caisses Desjardins du Québec, both of Lévis, Canada, Caisse central Desjardins du Québec, Montreal, Canada, and Desjardins FSB Holdings, Inc., Hallandale, Florida, to be treated as financial holding companies are effective.
September 29, 2015 (PDF)
Letter to Randall S. Theisen, Esq., granting a request by Western Alliance Bancorporation, Phoenix, Arizona, for a general exemption pursuant to the Depository Institution Management Interlocks Act and the Board's Regulation L to allow Mr. Howard Gould to serve as a director of Western Alliance while also serving as a management official of CCFW, Inc., d/b/a Carpenter & Company, Irvine, California, and certain affiliated entities.
July 17, 2015 (PDF)
Letter to Dr. Nico Zachert granting requests by FMS Wertmanagement, Munich, Germany for (1) a temporary exemption under section 4(c)(9) of the Bank Holding Company Act (12 U.S.C. section 1843(c)(9)) from the nonbanking restrictions of the Act, 2) a temporary exemption from certain reporting, filing, and capital requirements, and 3) an extension of the compliance date for applicable enhanced prudential standards.
June 18, 2015 (PDF)
Letter to Derek M. Bush, Esq., that the elections filed by KB Financial Group Inc. and its subsidiary bank, Kookmin Bank, both of Seoul, Korea, to be treated as financial holding companies are effective.
April 1, 2015 (PDF)
Letter to Scott Akins, Esq., granting a request by Freestone Capital Management, LLC, Seattle, Washington, and certain related entities for relief from commitments made to the Board in connection with the acquisition of voting shares in Cordia Bancorp, Inc., the parent of Bank of Virginia, both of Midlothian, Virginia.
February 18, 2015 (PDF)
Letter to Adam D. Nelson granting a request by Triumph Bancorp, Inc., Dallas, Texas, for an exemption from a prohibition of the Depository Institution Management Interlocks Act and the Board’s Regulation L to allow Mr. Derek McClain to serve as a management official of Triumph Bancorp while also serving as a management official of Mutual of Omaha Insurance Company and United of Omaha Life Insurance Company, both of Omaha, Nebraska.
January 29, 2015 (PDF)
General Counsel opinion letter to Joseph P. Daly opining that no regulatory purpose would be served by requiring a filing under the Home Owners’ Loan Act and the Federal Reserve Board’s Regulation LL, for Putnam County Savings Bank, a mutual savings bank, Brewster, New York, to acquire CMS Bancorp, Inc., a savings and loan holding company, White Plains, New York, and its wholly owned subsidiary, CMS Bank, a state savings bank, Mount Vernon, New York.
January 29, 2015
Letters to Emanuel J. Friedman granting requests by EJF Capital LLC, Arlington, Virginia, for relief from commitments it made to the Board in connection with its acquisition of securities that were issued by Franklin Bancorp, Inc. (PDF), Washington, Missouri; Alliance Financial Services, Inc. (PDF), St. Paul, Minnesota; Bank of George (PDF), Las Vegas, Nevada; and Old Second Bancorp, Inc. (PDF), Aurora, Illinois, to the Department of the Treasury as part of the Troubled Asset Relief Program's Capital Purchase Program.
January 29, 2015 (PDF)
Letter to Ryan Zacharia granting the request by JAM Partners, LP; JAM Managers, LLC; JAM Special Opportunities Fund III, LP; JAM Equity Partners, LLC; Investure Global Equity (JAM), LLC; Investure Global Equity Fund, LP – All Asset Series; Investure Global Equity (GP), LLC; Investure, LLC; and Jacobs Asset Management, LLC, all of New York, New York, for relief from commitments that were made in connection with their acquisition of securities that were issued by HMN Financial Inc., Rochester, Minnesota, to the Department of Treasury as part of the Troubled Asset Relief Program’s Capital Purchase Program.
January 29, 2015 (PDF)
Letter to Ryan Zacharia granting the request by JAM Partners, LP; JAM Managers, LLC; Investure Global Equity, LLC; Investure Global Equity Fund, LP – All Asset Series; Investure Global Equity (GP), LLC; Investure, LLC; and Jacobs Asset Management, LLC, all of New York, New York, for relief from commitments that were made in connection with their acquisition of securities that were issued by National Bancshares Inc., Bettendorf, Iowa, to the Department of Treasury as part of the Troubled Asset Relief Program’s Capital Purchase Program.