The Agencies and CSBS are issuing this guidance to clarify supervisory expectations for regulatory conversion requests subject to Section 612 of the Dodd-Frank Act.
Section 612 prohibits charter conversions by certain financial institutions subject to a cease and desist order (or other formal enforcement order) or a memorandum of understanding relating to a significant supervisory matter.
Institutions may request an exception to the conversion prohibition as described in Section 612(d).
The Agencies expect that exceptions will be rare and generally would occur only when the provisions of an enforcement action have been substantially addressed.
The July 2009 FFIEC Statement on Regulatory Conversions remains in effect.
FDIC-Supervised Banks (Commercial and Savings)
Chief Executive Officer
Interagency Statement on Section 612 of the Dodd-Frank Act, Restrictions on Conversions of Troubled Banks
William R. Baxter, Sr. Examination Specialist, at firstname.lastname@example.org or (202) 898-8514
Mark Flanigan, Counsel, at email@example.com or (202) 898-7426
FDIC Financial Institution Letters (FILs) may be accessed from the FDIC's Web site at
To receive FILs electronically, please visit http://www.fdic.gov/about/subscriptions/index.html.
Paper copies may be obtained through the FDIC's Public Information Center, 3501 Fairfax Drive, E-1002, Arlington, VA 22226 (1-877-275-3342 or 703-562-2200).