Legal Interpretations
Bank Holding Companies/Savings and Loan Holding Companies/Change in Control - 2026 Letters
May 18, 2026 (PDF)
Letter to William W. Templeton, Esq., advising that Bank of America Corporation ("BAC") may enter into long-term electricity supply contracts as an activity that is complementary to BAC's financial activity of engaging as principal in commodity derivatives transactions.
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.
January 9, 2026 (PDF)
Letter to Luigi L. De Ghenghi, Esq., granting requests by State Street Corporation and State Street Bank and Trust Company, both of Boston, Massachusetts, to treat an issuance of credit-linked notes, and substantially identical credit-linked-note transactions, as synthetic securitizations because they are similar to and at least as effective as transactions commonly used for mitigating risk that the Board recognizes in its capital rule.