Legal Interpretations
Bank Holding Companies/Savings and Loan Holding Companies/Change in Control - 2026 Letters
March 10, 2026 (PDF)
Letter to Kerri Bernstein granting a request by American Express Company, New York, New York, for one-year extensions of time to (1) submit an implementation plan to the Board, pursuant to section 217.121 of the Board’s Regulation Q, and to begin to comply with the advanced approaches capital adequacy framework and the related FFIEC 101 reporting requirements applicable to Category II banking organizations; and (2) comply with the deduction thresholds for deferred tax assets applicable to Category II banking organizations under section 217.22(d)(2) of the Board’s Regulation Q.
Last Update:
April 14, 2026