Legal Interpretations
Federal Reserve Act - 2008 Letters
December 29, 2008 (PDF)
Letter to H. Rodgin Cohen, Esq., Sullivan & Cromwell LLP, granting an exemption from Section 23A of the Federal Reserve Act (12 U.S.C. 371c) and the Board's Regulation W (12 CFR Part 223) for Wachovia Bank, National Association, Charlotte, North Carolina, to purchase auction-rate securities (“ARS”) from an affiliate.
December 24, 2008 (PDF)
Letter to Richard K. Kim, Esq., Wachtell, Lipton, Rosen & Katz, granting an exemption from Section 23A of the Federal Reserve Act (12 U.S.C. 371c) and the Board's Regulation W (12 CFR Part 223) to allow GMAC Bank, Midvale, Utah, to lend to consumers to enable them to purchase automobiles from unaffiliated dealers in the United States that obtain floorplan financing from affiliates of GMAC Bank.
December 1, 2008 (PDF)
Letter to a bank granting an exemption from section 23A of the Federal Reserve Act (12 U.S.C. 371c) and Regulation W (12 CFR Part 223) for certain asset purchases by the bank from its affiliated money market mutual funds.
November 24, 2008 (PDF)
Letter to Daniel F. Kaplan, Esq., Perry, Guthery, Haase & Gessford, P.C., L.L.O., granting an exemption from Section 23A of the Federal Reserve Act (12 U.S.C. 371c) and the Board's Regulation W (12 CFR Part 223) to allow Union Bank and Trust Company to purchase federally guaranteed student loans from an affiliate, Nelnet, Inc, all of Lincoln, Nebraska.
November 20, 2008 (PDF)
Letter to John David Wright, Esq., Wells Fargo Bank, N.A.("Bank"), San Francisco, California, granting a temporary exemption from Section 23A of the Federal Reserve Act (12 U.S.C. 371c) and the Board's Regulation W (12 CFR Part 223) to allow Bank to extend credit to its affiliate, Wachovia Bank, National Association, Charlotte, North Carolina.
October 29, 2008 (PDF)
Letter to John David Wright, Esq., Wells Fargo Bank, N.A., San Francisco, California, granting an exemption from Section 23A of the Federal Reserve Act (12 U.S.C. 371c) and the Board's Regulation W (12 CFR Part 223) to purchase assets and loan commitments from four nonbank affiliates in connection with the proposed reorganization of the affiliates.
October 6, 2008 (PDF)
Letter to a bank granting an exemption from section 23A of the Federal Reserve Act (12 U.S.C. 371c) and the Board's Regulation W (12 CFR Part 223) for certain asset purchases by the bank from its affiliated money market mutual funds.
July 23, 2008 (PDF)
Letter to Randall J. Erickson, Esq., Marshall & Ilsley Corporation, Milwaukee, Wisconsin (M&I"), addressing the circumstances under which Board staff would not recommend that the Board determine that Metavante is an affiliate of the subsidiary depository institutions of M&I for purposes of section 23A of the Federal Reserve Act (12 U.S.C. 371c) and the Board's Regulation W (12 CFR Part 223).
July 1, 2008 (PDF)
Letter to Kathryn V. McCulloch, JPMorgan Chase & Co. ("JPMC"), New York, New York, granting an exemption from section 23A of the Federal Reserve Act (12 U.S.C. 371c) and the Board’s Regulation W (12 CFR Part 223) for certain covered transactions between JPMorgan Chase Bank, National Association, and its affiliates in connection with JPMC’s acquisition of The Bear Stearns Companies, Inc., New York, New York.
June 26, 2008 (PDF)
Letter to Kathleen A. Juhase, Esq., JPMorgan Chase & Co. (“JPMC”), New York, New York, granting an exemption from section 23A of the Federal Reserve Act (12 U.S.C. 371c) and the Board's Regulation W (12 C.F.R. Part 223) for transactions entered into by JPMorgan Chase Bank, National Association, Columbus, Ohio, with or relating to Maiden Lane LLC.
May 19, 2008 (PDF)
Letter to A. Patrick Doyle, Arnold & Porter LLP, granting an exemption from section 23A of the Federal Reserve Act and Regulation W (12 U.S.C. 371c and 12 CFR Part 223) for certain transactions between Merrill Lynch Bank & Trust Co., FSB ("MLFSB"), New York, New York, and First Franklin Financial Corporation ("First Franklin"), San Jose, California, that will become covered transactions on the transfer by MLFSB of its ownership interest in First Franklin to its affiliate, Merrill Lynch Mortgage Services Corporation.
April 1, 2008 (PDF)
Letter to Kathleen A. Juhase, Esq., JPMorgan Chase & Co. (“JPMC”), New York, New York, (i) granting a temporary exemption from section 23A of the Federal Reserve Act (12 U.S.C. 371c) and the Board’s Regulation W (12 CFR Part 223) for certain covered transactions between JPMorgan Chase Bank, National Association, and its affiliates in connection with JPMC’s acquisition of The Bear Stearns Companies, Inc. (“Bear Stearns”), New York, New York; and (ii) providing JPMC with a transition period to incorporate fully the assets and exposures of Bear Stearns into JPMC for purposes of the Board’s risk-based and leverage capital guidelines for bank holding companies (12 CFR Part 225, Appendices A and D).
March 25, 2008 (PDF)
Letter to Karen Grandstrand, Esq., Minnwest Corporation, Minnetonka, Minnesota, granting an exemption from section 23A of the Federal Reserve Act and Regulation W (12 U.S.C. 371c and 12 C.F.R. Part 223) in order that (i) its wholly owned subsidiary, Minnwest Bank Metro, Rochester, Minnesota, may acquire all the shares of an affiliate, Minnwest Capital Corporation ("MCC"), also in Minnetonka, and (ii) Minnwest's wholly owned subsidiary Minnwest Bank, Redwood Falls, Minnesota, may purchase from Metro Bank certain lease participations originated by MCC immediately after the transfer of MCC to Minnwest Bank Metro.