Legal Interpretations
Bank Holding Companies/Savings and Loan Holding Companies/Change in Control - 2020 Letters
December 30, 2020 (PDF)
Letter to Alan W. Avery, Esq., advising that staff would not recommend that the Board find National Bank of Canada, Montreal, Canada, to control Fiera Capital Corporation under the Bank Holding Company Act of 1956, as amended, based on the facts and circumstances described in the letter and related correspondence.
December 30, 2020 (PDF)
Letter to Javier A. Alvarez, Esq., granting a request by certain shareholders of Ocean Bankshares, Inc., for limited relief from commitments made to the Board in connection with their interests in Ocean Bankshares, Inc.
December 21, 2020 (PDF)
Letter to Annie Loo, Esq., granting a request by SVB Financial Group for a one-year extension of time to conform to the requirements of the Board’s Regulation VV certain investments it holds, indirectly, as a result of its acquisition of Leerink Holdings LLC.
December 3, 2020 (PDF)
Letter to William J. Sweet, Jr., advising that BlackRock, 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.
December 1, 2020 (PDF)
Letter to Ross Oklewicz, Esq., not objecting to the Change in Bank Control Act notice filed by The Vanguard Group, Inc. (“VGI”), Malvern, Pennsylvania, on behalf of itself, its subsidiaries and affiliates, and the investment companies registered under the Investment Company Act of 1940, other pooled investment vehicles, and institutional accounts that are sponsored, managed, or advised by VGI, to acquire aggregate control of 15 percent or more of KeyCorp, parent of KeyBank, National Association, both of Cleveland, Ohio.
November 20, 2020 (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.
November 20, 2020 (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 10, 2020 (PDF)
Letter to Paul W. Scott, Esq., not objecting to the Change in Bank Control Act notice filed by The Vanguard Group, Inc. (“VGI”), Malvern, Pennsylvania, on behalf of itself, its subsidiaries and affiliates, and the investment companies registered under the Investment Company Act of 1940, other pooled investment vehicles, and institutional accounts that are sponsored, managed, or advised by VGI, to acquire aggregate control of 15 percent or more of Citizens Financial Group, Inc., parent of Citizens Bank, National Association, both of Providence, Rhode Island.
November 3, 2020 (PDF)
Letter to Andrew S. Baer, Esq. granting a request by Morgan Stanley, New York, New York, and related entities and affiliates, for relief from commitments made to the Board in connection with their interests in shares of Carver Bancorp, Inc., New York, New York.
October 1, 2020 (PDF)
Letter to Rebecca J. Simmons, Esq., granting in part and denying in part a request by The Bank of New York Mellon Corporation, New York, New York, for an exemption from certain requirements of the Board's QFC stay rule for certain custody services contracts.
October 1, 2020 (PDF)
Letter to Rebecca J. Simmons, Esq., granting in part and denying in part a request by State Street Corporation, Boston, Massachusetts, for an exemption from certain requirements of the Board's QFC stay rule for certain custody services contracts.
October 1, 2020 (PDF)
Letter to Rebecca J. Simmons, Esq., granting in part and denying in part a request by JPMorgan Chase & Co., New York, New York, for an exemption from certain requirements of the Board's QFC stay rule for certain custody services contracts.
October 1, 2020 (PDF)
Letter to Rebecca J. Simmons, Esq., granting in part and denying in part a request by Citigroup Inc., New York, New York, for an exemption from certain requirements of the Board's QFC stay rule for certain custody services contracts.
October 1, 2020 (PDF)
Letter to Rebecca J. Simmons, Esq., granting in part and denying in part a request by Bank of America Corporation, Charlotte, North Carolina, for an exemption from certain requirements of the Board's QFC stay rule for certain custody services contracts.
October 1, 2020 (PDF)
Letter to Gabriel Rosenberg, Esq., granting a request by Wells Fargo & Company, San Francisco, California, for an exemption from certain requirements of the Board's QFC stay rule for certain non-U.S., non-linked contracts.
October 1, 2020 (PDF)
Letter to Gabriel Rosenberg, Esq., granting a request by Morgan Stanley, New York, New York, for an exemption from certain requirements of the Board's QFC stay rule for certain non-U.S., non-linked contracts.
October 1, 2020 (PDF)
Letter to Gabriel Rosenberg, Esq., granting a request by JPMorgan Chase & Co., New York, New York, for an exemption from certain requirements of the Board's QFC stay rule for certain non-U.S., non-linked contracts.
October 1, 2020 (PDF)
Letter to Gabriel Rosenberg, Esq., granting a request by The Goldman Sachs Group, Inc., New York, New York, for an exemption from certain requirements of the Board's QFC stay rule for certain non-U.S., non-linked contracts.
October 1, 2020 (PDF)
Letter to Gabriel Rosenberg, Esq., granting a request by Citigroup Inc., New York, New York, for an exemption from certain requirements of the Board's QFC stay rule for certain non-U.S., non-linked contracts.
October 1, 2020 (PDF)
Letter to Gabriel Rosenberg, Esq., granting a request by Bank of America Corporation, Charlotte, North Carolina, for an exemption from certain requirements of the Board's QFC stay rule for certain non-U.S., non-linked contracts.
June 29, 2020 (PDF)
Letter to Rebecca J. Simmons, Esq., granting a request by JPMorgan Chase & Co., New York, New York, for an extension of time until October 1, 2020, to conform certain custody services contracts to certain requirements of the Board's QFC stay rule.
June 29, 2020 (PDF)
Letter to Rebecca J. Simmons, Esq., granting a request by State Street Corporation, Boston, Massachusetts, for an extension of time until October 1, 2020, to conform certain custody services contracts to certain requirements of the Board's QFC stay rule.
June 29, 2020 (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 October 1, 2020, to conform certain custody services contracts to certain requirements of the Board's QFC stay rule.
June 29, 2020 (PDF)
Letter to Rebecca J. Simmons, Esq., granting a request by Bank of America Corporation, Charlotte, North Carolina, for an extension of time until October 1, 2020, to conform certain custody services contracts to certain requirements of the Board's QFC stay rule.
June 29, 2020 (PDF)
Letter to Rebecca J. Simmons, Esq., granting a request by Citigroup Inc., New York, New York, for an extension of time until October 1, 2020, to conform certain custody services contracts to certain requirements of the Board's QFC stay rule.
June 29, 2020 (PDF)
Letter to Gabriel Rosenberg, Esq., granting a request by Citigroup Inc., New York, New York, for an extension of time until October 1, 2020, to conform certain non-U.S., non-linked contracts to certain requirements of the Board's QFC stay rule.
June 29, 2020 (PDF)
Letter to Gabriel Rosenberg, Esq., granting a request by Wells Fargo & Company, San Francisco, California, for an extension of time until October 1, 2020, to conform certain non-U.S., non-linked contracts to certain requirements of the Board's QFC stay rule.
June 29, 2020 (PDF)
Letter to Gabriel Rosenberg, Esq., granting a request by Bank of America Corporation, Charlotte, North Carolina, for an extension of time until October 1, 2020, to conform certain non-U.S., non-linked contracts to certain requirements of the Board's QFC stay rule.
June 29, 2020 (PDF)
Letter to Gabriel Rosenberg, Esq., granting a request by Morgan Stanley, New York, New York, for an extension of time until October 1, 2020, to conform certain non-U.S., non-linked contracts to certain requirements of the Board's QFC stay rule.
June 29, 2020 (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 October 1, 2020, to conform certain non-U.S., non-linked contracts to certain requirements of the Board's QFC stay rule.
June 29, 2020 (PDF)
Letter to Gabriel Rosenberg, Esq., granting a request by JPMorgan Chase & Co., New York, New York, for an extension of time until October 1, 2020, to conform certain non-U.S., non-linked contracts to certain requirements of the Board's QFC stay rule.
February 13, 2020 (PDF)
Letter to Joseph P. Vitale, Esq. granting a request by Stephen A. Feinberg, Cerberus Capital Management, L.P., and certain related entities for relief from commitments made to the Board in connection with their interests in shares of Ally Financial, Inc. (formerly, GMAC LLC).