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Federal Deposit
Insurance Corporation

Each depositor insured to at least $250,000 per insured bank

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FDIC Federal Register Citations


On Monday, April 5, 2004 Senior Deputy General Counsel Doug Jones, Assistant General Counsel John Thomas, Senior Counsel Marilyn Anderson, Counsel Pam LeCren (FDIC Legal), and Chief of Planning and Program Development Serena Owens (FDIC DSC) met with staff from the Conference of State Bank Supervisors (CSBS) (Buz Gorman, Montrice Yakimov and Alan Cox) regarding the FDIC’s proposed Part 324 which, if adopted, would apply the substantive provisions of Federal Reserve Board (FRB) Regulation W (implementing sections 23A and 23B of the Federal Reserve Act) to insured state nonmember banks. The meeting was held in response to FDIC’s offer to sit down with CSBS staff to explain the background for the proposal and to answer any questions CSBS staff might have on the proposal. FDIC staff started the meeting by providing general information on the background of the proposal followed by a brief overview of the proposal. FDIC staff also mentioned concerns raised by two of the FDIC’s Directors at the March 10 Board of Directors meeting that the proposal might put state banks in an awkward position given concerns informally raised by the General Counsel of the FRB about the proposal and FDIC’s authority to adopt it. CSBS inquired about the FDIC’s position on the issues raised by the FRB’s General Counsel and Doug Jones briefly walked through the source of the FDIC’s authority for the proposal and informed CSBS staff that, as reflected in the proposal and as stated at the FDIC’s Board meeting, it is staff’s intent to coordinate closely with the FRB in the administration of sections 23A and 23B as to insured state nonmember banks. CSBS staff indicated that they felt that it is, in their view, very important that the FDIC and FRB find a way to avoid subjecting banks to conflicting directions from two regulators. FDIC responded to several questions concerning the proposed exemption for certain subsidiaries that were in existence prior to March 10, 2004 as well as a question on how the proposal would impact bank capital. CSBS staff indicated that they had not had the opportunity to review the proposal in depth but that it was their intent to do so and that CSBS would consider filing a formal comment. FDIC staff called to their attention that the FDIC had requested comment on 15 specific questions and indicated that if a comment is filed it would be most useful in terms of providing guidance to the agency if the comment was as specific as possible. In closing CSBS staff said that it is supportive of state banks taking advantage of powers granted by the states and would like to see an operating environment that allows that to continue.

Last Updated 04/09/2004

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