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Highlights:
- Financial institutions may choose to operate under the state or federal charter that best
accommodates their legitimate business and strategic needs.
- Conversion requests submitted while serious or material enforcement actions are pending should
not be entertained.
- Institutions that intend to change their charter or banking supervisor will continue to seek
approval through an application process with the prospective chartering authority and primary
federal regulator, in consultation with state authorities.
- Ratings assigned under the banking agencies' uniform rating systems and outstanding corrective
programs will remain in place following a charter conversion and/or supervisory agency change.
- Any regulatory conversion request involving an institution with a current or proposed rating of
3, 4, or 5 (or "Needs Improvement" or "Substantial Noncompliance" regarding Community
Reinvestment Act performance), or is subject to a current or pending corrective program that is
serious or material will require consultation by the prospective supervisor with the FDIC and
with the Federal Reserve Board as holding company supervisor.
- The prospective supervisor may choose to conduct an eligibility examination and may invite the
current supervisor to participate.
Distribution:
All FDIC-Supervised Institutions
Suggested Routing:
Chief Executive Officer
Attachment:
FFIEC Statement on Regulatory Conversions
Contact:
William R. Baxter, Sr. Examination Specialist,
202.898.8514 or wbaxter@fdic.gov
Note:
FDIC financial institution letters (FILs) may be
accessed from the FDIC's Web site at
www.fdic.gov/news/news/financial/2009/index.html.
To receive FILs electronically, please visit
http://www.fdic.gov/about/subscriptions/fil.html.
Paper copies of FDIC financial institution letters may
be obtained through the FDIC's Public Information
Center, 3501 Fairfax Drive, E-1002, Arlington, VA
22226.
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