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4000 - Advisory Opinions


Letter No.
83-20 Establishment of Collective Investment Pool
86-6 Eligibility of Federal Reserve Member Commercial Bank to Become an FDIC-Insured Federal Savings Bank
86-14 FDIC-Insured Industrial Loan Company Subject to Federal Reserve Regulation AA, Not to Federal Trade Commission Rule
86-41 Establishment of Captive Insurance Company to Provide Directors Liability Insurance for Commercial Banking Industry
87-3 Directors and Officers Liability Insurance as Members of a Mutual Insurance Company
87-27 Voluntary Termination of FSLIC Status Under the CEBA
87-31 Disclosure Requirements Upon Renegotiation of Fixed-Rate Mortgages
87-39 Questions Concerning FDIC Enforcement of the Equal Credit Opportunity Act
87-43 Eligibility of Rural Electric Association Cooperative to Hold Funds in NOW Account
87-49 Deposit Notes are Certificates of Deposit
87-58 Inclusion of Preissued, Postdated Cashier's Checks in FDIC Deposit Assessment
87-59 Treatment of Electronic Debits Arising from Use of Automated Teller Machine Network and/or Debit Card (Point of Sale) Network When a Participating Bank Closes Prior to Final Settlement
88-10 Notice to FDIC Involving Transfer of Assets Between FDIC-Insured and FSLIC-Insured Institutions
88-28 FDIC Prior Approval of the Transfer of Deposit Liabilities
88-44 Procedures for Obtaining FDIC Insurance Coverage on "Deposit Notes"
88-59 Management Interlocks with Federal Land Bank Association
88-64 Tax Allocation Agreement Between Bank and Bank Holding Company
88-68 Amendment of Stock Option Plan Without Shareholder Approval
88-69 Affiliated Banks Acting as Branches for Each Other
88-78 Posting FDIC Signs in Embassy Branches
89-6 Stock Option Plan for Disinterested Non-Employee Director
89-9 Home-Improvement Loan Applications May Be Excluded When Calculating Home Loan Applications Received During 1988
89-42 FDIC Insurance for Branches Located in the United States Virgin Islands
89-44 Equal Credit Opportunity Act: Reg B
89-45 Deposit Insurance Coverage is not Determined by Tax Identification Numbers (Social Security Numbers)
90-5 Definition of "Loan Commitment"
90-7 Question Whether FDIC Advance Approval is Required for Submission by a Bank of Any Matter to a Shareholder Vote; Shareholder Proposals
90-15 Undisbursed Loan Proceeds of a Multiple Advance Loan: Part 325 - Capital Adequacy
90-18 Employee Stock Ownership Plan: Collateral Loan
90-24 Deposit Broker Engaged in the Business of Placing Deposits, or Facilitating the Placement of Deposits
90-40 Domestic Brokered Deposits of Foreign Bank Customer Funds: Recordkeeping Requirements
90-57 Third-Party Seller of Certificate of Deposit is Insured When Insured Depository Institution Issuing Certificate Defaults Prior to Negotiation of Certificate to Buyer
90-62 Eligibility of 403-B Plan Account for Deposit Insurance
90-64 Technical Questions Concerning Display of Official FDIC Logo in Banks
90-78 Insured Depository Institutions May Pass Cost of Federal Deposit Insurance Directly to Depositors Provided Notice is Given
91-3 FDIC Defers to Federal Reserve Board's Interpretation of NOW Accounts (12 C.F.R. § 204.130)
91-18 Circumstances in Which Advance Notice is Required Under 12 C.F.R. § 304.6
91-19 Whether ATM Promotion Constitutes Payment of Interest on Demand Deposits in Violation of 12 C.F.R § 329
91-21 Deposit Insurance Coverage Afforded Funds Held by Money Order Company and Funds Held by Depository Institution as Agent for Money Order Company
91-22 Questions Concerning Safety and Insurance of Funds Placed in a Money Market Fund Investing in Short-Term U.S. Government Securities
91-30 Insured Depository Institutions May Not Charge Customers a Fee for Cost of Deposit Insurance in Excess of Actual Cost
91-34 Banking Institutions Providing Services to Customers of Affiliated Institutions Pursuant to New Jersey Statute Must Comply with Procedures for Establishing a Branch Office Under 12 C.F.R. Part 303
91-46 Whether Appraisal-Type Functions May Be Performed by Uncertified and Unlicensed Appraisers Under USPAP Standards and 12 C.F.R. § 323.5(b)
91-54 Examiner Discretion in Determining What Minimum Security Devices and Procedures Meet the Requirements of 12 C.F.R. § 326.3 Under the Circumstances
91-73 Applicability of Community Reinvestment Act to Trust Company
91-77 Federal Deposit Insurance Act Does Not Distinguish Between Secured and Unsecured Deposits for Assessment Purposes
91-79 An Electric Cooperative is Eligible to Hold a NOW Account Under Revised Federal Reserve Board Regulations (12 C.F.R. § 204.130)
91-83 Application of "Insubstantial Portion" Exception to Conversion Transaction Moratorium Where Bank Merges with Trust Company Which Does Not Hold Deposits
92-10 Whether Master Repurchase Agreement and Side Letter Entered into by Insured Bank and Its Trust Department Constitute a Deposit for Assessment Purposes
92-34 Application of Section 19 of the FDI Act to Contractual Agreement Between Bank and Company Owned by Individual Convicted of Crime Involving Dishonesty and Breach of Trust
92-40 Split-Dollar Insurance Arrangement Insuring Employee of Bank but Naming Bank's Holding Company as Beneficiary Violates Section 23B of the Federal Reserve Act
92-41 Assessibility of Deferred Credit Portion of Cash Letters Collected Through Federal Reserve by Bankers Bank as Agent for Its Correspondent Banks
92-47 Section 521 of the Depository Institutions Deregulation and Monetary Control Act of 1980 Authorizes Insured State-Chartered Banks to Export Same Fees and Charges on Interstate Loans that National Banks May Under 12 U.S.C. § 85
92-59 Depository Institutions May Enter Into Reciprocal Agreement With Another Depository Institution to Provide Equipment Backup in Event of Emergency
92–85 Unaffiliated Entity Which Provides "Back Office" Processing Services on Behalf of an Insured State Nonmember Bank Is not Considered a Branch
92–95 Branch Closing Notice Requirements Are Not Triggered by Closing of an Insured State Bank's Principal Office
93-17 Illustrative Violation of Section 19 of the FDI Act
93-20 Temporary Employee Working for Insured Depository Institution Is Subject to Section 19 of the FDI Act
93-27 12 U.S.C. § 1831d Preempts Contrary State Common Law Restrictions on Credit Card Loans
93-53 Profit-Sharing Plan Controlled by Large Shareholder of Bank Is an Affiliate Under Section 23A of Federal Reserve Act
93-55 Bank Must Report Funds Collected From Purchases of American Express Official Checks as Deposits in Its Call Report
93-67 Regulation DD—Tiered-Rate Accounts and Disclosure Statement Requirements
93-75 Whether ESOP is an Affiliate for Purposes of Section 23A
93-82 Whether Excess Funds From "Sweep" Accounts May Be Transferred to Interest Bearing Account
94-2 Whether Loan Application Forms May Contain Check Boxes to Assist Creditors in Complying with the ECOA and Regulation B
94-21 Users' Rights Under the Electronic Funds Transfer Act in the Event of Bank Error Regarding an Electronic Wire Transfer
94-25 Whether a Bank Executive Convicted Under 31 U.S.C. § 5322(a) for "Willful Failure to Report Currency Transactions" Is a Crime Under Section 19 of the FDI Act
94-26 Whether a Bank Executive Convicted of Embezzlement and Subsequently Pardoned by the President of the U.S. Is Subject to the Provisions of Section 19 of the FDI Act
94-27 Applicability of Section 19 of the FDI Act When Pretrial Diversion Agreement Was Entered Into Before the Issuance of Formal Criminal Process
94-28 Whether Section 19 Application Is Required in Connection With a Conviction for Retail Theft Under Pennsylvania Law
94-29 "Pre-Trial Diversion Agreements and Other Similar Programs" Language in Section 19 Cases
94-34 Appraisals: Loans to Non-Profit Corporations May Qualify Under Business Loan Exemption
94-35 Whether the Issuance of Large Denomination CD's Causes a Trust Company to Lose It's Exemption From the CRA Regulations
94-44 Request for Exemption from Appraisal Requirement
94-56 Reporting of Unused Portions of Approved Lines of Credit
95-19 Transaction with Affiliated Equipment Leasing Company—Applicability of § 23A, § 23B and 12 CFR § 250.250
95-20 Bank Acceptance of Loan Guarantee From Foreign Affiliate Subject to § 23A of Federal Reserve Act
95-22 Interstate Contract Branching Arrangements Between State Nonmember Banks and Other Banks Permissible Subject to Same Conditions Imposed on Intrastate Contract Branching Arrangements
95-28 Whether a Loan Production Office of an Insured Non-member Bank Qualifies as a "Domestic Branch" as Defined in § 3(o) of the FDI Act
95-29 Bank Award of Bonus Points and/or Gift Certificates for Use of a Credit Card Does not violate § 329 as Long as Credit Card Is Not Linked to a Demand Deposit Account
95-32 Bank Program Giving Certain Customers Automatically Reduced Interest Rates on Loan Does Not Violate Prohibition Against Tying Arrangements, but Could Violate ECOA or FHA
96-2 Applicability of § 23A of the Federal Reserve Act to a Transaction Involving an Insured Nonmember Bank, an Unaffiliated Purchaser of the Bank's Affiliated Savings Bank, and the Holding Company Owning Both the Bank and Savings Bank
96-5 Applicability of Section (c)(1) of the Bank Merger Act to a Proposed Acquisition Involving the Purchase of Uninsured Subsidiaries
96-8 Applicability of § (a)(1)(2) ("Attribution Rule") to Loans Made by a Bank Which Benefits an Affiliate of the Bank
97-2 Applicability of the Golden Parachute Regulation to the Proposed Serverance Payment to a Former Executive of a National Bank
97-6 Would Certain Courier/Messenger Services Constitute Branch Banking, Therefore, Violate Branch Banking Laws
99-2 Back Office Facilities Operated by Subsidiaries
00-5 Whether a New York-chartered Bank is Allowed Under Sections 18(d)(1) and 44(d)(2) of the FDI Act to Establish Additional Branches in California
02-06 Does section 27 of the Federal Deposit Insurance Act preempt the Michigan Motor Vehicle Sales Finance Act 
03-04 Would a Part 362 application be necessary in order for a state-chartered nonmember bank to acquire as a subsidiary, a sports agency that would represent professional athletes and coaches 
04–09 How the "Attribution Rule" of the Federal Reserve Act Apply to Certain Credit Transactions 
06-01 Questions Regarding Interstate Contract Branching Under Section 18(r) of the FDI Act
06-02 State restrictions on the Establishment of Interstate De Novo Branches by Industrial Loan Companies

Powers Inconsistent With Purposes of Federal Deposit Insurance Law

Letter No.
80-14 Participation Agreement—Application of Part 332
80-18 Agreement to Sell Loans Servicing Rights
80-19 Bank Check Guarantee Card Arrangements
81-15 Employee stock Ownership Plan (ESOP)
81-21 Bank Guaranty of Obligations of Others is Not Standby Letter of Credit
82-6 Relationship Between FDIC's Regulations (Part 332) and the Florida Security for Public Deposits Act
82-11 Expansion of Bank's Money Order Operation Not in Violation of Part 332 of FDIC's Regulation
82-17 Apparent Violation of Section 332.1 of FDIC Regulations
82-18 Apparent Violation of Section 332.1 of FDIC Regulations
82-19 Insured Nonmember Bank Receiving and Disbursing Foreign Bank Loan Proceeds
83-3 Exception to Section 332.1 of FDIC's Regulations Prohibiting the Guarantee of Real Estate Titles
83-4 Guarantee of Obligations of Bank's Wholly Owned Subsidiaries Not in Violation of Part 332
83-5 Conflict of South Dakota Banking Law with Part 332 of FDIC's Regulations
83-8 Guaranteeing the Obligations of Others: Substantial Interest Exception
83-9 Letter of Credit Issued to Insurance Company Not in Violation of Part 332
83-10 Bank Guaranty Not in Violation of Part 332 Due to Substantial Interest Exception
83-11 Guarantee of Small Business Administration Loan Payment
84-1 Exceptions to the Prohibitions on Bank Guarantees
84-11 Applicability of Part 332 to Repurchase and Resale of Industrial Development Bonds by Insured State Nonmember Bank
84-15 "Special Interest" Exception to Part 332 Prohibition on Bank Guarantees
84-18 Nonbank Activities of Nonmember Bank
84-22 Third-Party Loan Guarantee to Bank ESOP Plan for Bank Stock Purchase
85-1 Dealer's Bank Agreement Conforms to 12 CFR 337.2 Definition of Standby Letter of Credit
85-8 Sale of Bonds from Bank's Investment Portfolio Pursuant to a Collaterized Put
85-20 Sale of Bonds from Bank's Investment Portfolio Pursuant to a Collaterized Put Accounting Treatment
85-28 Guaranteeing the Fidelity of Debtors to a Federal Agency
86-1 Guarantee of Loans to Nonbanking Affiliates by Affiliated Banks Within a Bank Holding Company
86-4 Bank Sale of Automobile Warranty Is Not Within Scope of Traditional Banking Activities
86-16 Bank Guarantees of Customer Obligations Are Prohibited
86-20 Insurance Coverage of Lock Box Deposit Account Maintained by Real Estate Agent
86-39 Bank Agreement to Be Responsible to Customers and Clearing Broker for Any Loss of Funds Resulting from Misappropriation, Conversion or Errors Made by Bank Affiliated Broker-Dealer
87-5 Sale Leaseback of Bank Premises
90-38 Surety Activities By Subsidiary of State Nonmember Bank
91-67 Exemption for Customer-Sponsored Credit Card Programs Under 12 C.F.R. § 332.3 Does Not Extend to Credit Cards Issued to Businesses
92-27 Whether Certain Deposit Product Violates Prohibition Against Paying Interest on Demand Deposits (12 CFR 329.2)
92-81 After December 19, 1992, Insured State Banks May Not Invest in Tax Certificates Without FDIC's Consent
94-36 Effect of Proposed Holding Company Formation on the "Grandfathered" Status of a Subsidiary for Purposes of § 24(d) of the FDI Act
00-2 Would certain sweep accounts violate the Federal Deposit Insurance Act

Real Estate-Related Financial Transactions

Letter No.
90-72 Whether the Taking of Additional Real Estate Collateral Meets the Definition of "Real Estate-Related Transaction" under 12 C.F.R. § 323.2(g)
90-75 Whether a New Appraisal is Required Pursuant to 12 C.F.R. § 323 When a Line of Credit is Renewed and the Original Appraiser Was Not Certified
91-8 Whether Property Held in a Land Trust and Assigned as Collateral for Credit Line Which is Subsequently Increased Requires an Appraisal Under 12 C.F.R. § 323
91-12 Whether an Appraisal is Required Pursuant to 12 C.F.R. § 323 Where Additional Credit May be Advanced at Lender's Option Under Loan Agreement
91-63 Depository Institution's Nonrecourse Financing of Third Party's Purchase of Mortgage Loans for 90 Percent or 100 Percent of Purchase Price is Exempt Under FDIC's Appraisal Regulations (12 C.F.R. § 323)
91-82 Interpretation of 12 C.F.R. § 323.5 Where Mortgage Broker Acts as Agent for Institution in Ordering Appraisals
91-86 Deposits of Real Estate Trust Account ("RETA") Program Established by State Statute May, Like IOLTA Deposits, Be Held in NOW Accounts
91-90 Whether an Appraisal is Required Under 12 C.F.R. § 323.2(g) Where Real Estate Held as Collateral for Existing Loan Changes Legal Form and Where Institution Subordinates Its Interest In Leasehold Collateral to Subsequent Lender
92-1 Whether Cancelling Revolving Loan Commitment and Establishing Installment Payment Schedule Constitutes a "Real Estate-Related Financial Transaction" or "Refinancing of Real Property" Under 12 C.F.R. § 323.2(g)
92-5 Questions Concerning What Constitutes "Refinancing of Real Property" Under 12 C.F.R. § 323.2(g)(2)
92-7 Whether Institution Must Aggregate Indebtedness Owed to It by Same Borrower and Secured by Same Real Property in Determining "Transaction Value" Under 12 C.F.R. § 323.3(a)(1)
92-9 Situations in Which an Appraisal is Required Under 12 CFR Part 323
92-17 Whether Appraisal Is Required for Refinancings of FHA and VA Loans or with Loans Financing Purchase of Homes Acquired by FHA/VA Through Foreclosure Where no Current Appraisal Is Required Under FHA/VA Rules
92-46 FDIC Will Accept Continuity of Loan Purpose Where Loan Refinances Another loan Qualifying as a "Home Residence Loan"
92-62 Release of Collateral Is "Refinancing" Under 12 C.F.R. § 323.2(g)(2) if New Note Is Taken of if Release Constitutes a Material Modification of Original Loan Terms
92-78 FHA Trustees Servicing FHA-Related Mortgage Portfolios Are Not Subject to Brokered Deposit Registration Requirements
92–93 Appraisal Exemption May Not be Used to Condition Financing of Development Project Beyond $100,000 Upon Receipt of Appraisal; Total Amount Covered by Loan Is Transaction Value, Not Separate Value of Each Construction Project/Unit
93-23 New Appraisals of Real Estate Collateral not Required Where New Obligor Is Alter Ego of Prior Obligors and Where Four Criteria Set Forth in Refinancing Exemption (12 C.F.R. § 323.3(a)(4)) Are Met
93-25 Bank May Establish Line of Credit for Purpose of Funding Mortgage Loans Originated by Mortgage Company Subsidiary Under Section 23A of the Federal Reserve Act
93-38 Insurance Coverage of Mortgage Servicing Accounts Under New Rules
93-52 Application of Real Estate Lending Standards to Interim Construction Loan for Low-Income and Elderly Apartment Housing
93-76 Applying a Single Real Estate Lending Policy to Two Closely Affiliated Institutions
95-1 Riegle Community Development and Regulatory Improvement Act of 1994 Requires Use of Complete FEMA Map and Panel Number for Real Property Offered as Collateral for Loan
96-10 Loans Made by Insured Depository Institutions for Properties Located in Communities Not Participating in the National Flood Insurance Program

Receivership and Liquidation

Letter No.
84-19 Handling of Loan Participations Where Receiver is Appointed for Lead Bank
85-4 Insured Nonmember Banks Must Obtain Prior FDIC Consent to Repurchase Underlying Securities from Unit Investment Trust
86-8 Separate Corporate Identity of Subsidiary Established by Insolvent FDIC-Insured Institution in Connection with the Issuance of Mortgage Pay-Through Bonds or Preferred Stock
88-14 Deposit Insurance for U.S. Treasury Bills
88-15 Effect of Unposted Debts on Deposit Accounts at the Time a Bank Closed
88-21 Insurance Coverage of IRA Accounts
88-30 FDIC Policy Regarding Liquidation of Repurchase Transactions by Insolvent Banks
88-49 Close-Out of Forward Currency Obligations Owned by Banks in FDIC Receivership
88-80 Timing and Method of Paying Insured Deposits When FDIC-Insured Bank Fails
88-82 Documents Required When a Bank Fails and Records Are Missing, Incomplete or Incorrect
89-5 FDIC's Policy Regarding the Treatment of "SWAP" Transactions in Its Receiverships
89-37 Administrative Levies of the Internal Revenue Service Against Taxpayer Accounts in Closed Banks
89-48 Transactions in Which an Insured Depository Institution Grants a Security Interest in Assets of the Institution to a Third Party
89-49 Self-Help Liquidation of Collateral by Second Claimants in Insured Depository Institution Receiverships
91-2 Treatment of Payments Made to Bondholders Pursuant to Letters of Credit When Issuing Bank Becomes Insolvent
91-11 Whether FDIC as Receiver of a Failed Depository Institution Will Allow a Depositor to Offset Deposits Against Indebtedness Owed to Depository Institution
91-24 Avoidability of Security Interest in Collateral Pursuant to "Contemporaneous" Requirement of 12 U.S.C. §§ 1821(d), 1821(n)(4)(I) and 1823(e)
91-47 Insurance Coverage Afforded Deposit Accounts Containing Rollover Funds Awaiting Investment in Securities When Insured Bank Fails
91-48 Legal Memorandum in Support of FDIC and RTC Statements of Policy Regarding Payment of State and Local Property Taxes
91-71 Treatment of Securities Purchased by Trade Association Pursuant to Master Repurchase Agreement Between Association and Bank Upon Subsequent Failure of Bank
92–89 Disposition of Uncollected Cashier's Checks Upon Date of Depository Institution Default
93-10 Circumstances Under Which FDIC as Receiver Will Not Seek to Avoid Security Interest or Collateral Pledge Under 12 U.S.C. 1823(e)
93-61 Investment of Idle Custodial Funds in Repurchase Agreements by Agencies Selling Livestock on Commission Basis for Department of Agriculture
94-1 "Deposit Liability" for Purposes of National Depositor Preference Includes Only Deposits Payable in U.S.
94-23 The Status of American Depository Receipts
95-2 How Items in Process of Payment are Handled When Payor Bank Fails
97-1 Whether a Pledge of Assets by a Bank to Secure a Deposit by a Nonprofit Organization Would be Legally Enforceable in the Event of the Appointment of the FDIC as Receiver or Conservator for the Institution

Recordkeeping Requirements for Deposit Insurance

Letter No.
86-17 Recordkeeping Requirements for Deposit Insurance of Bearer Certificates of Deposit Held as Agent or Trustee
87-20 Fiduciary Records as Disclosure Requirements for Insurance Coverage
87-33 Insurance Coverage of Accounts Established for Workman's Compensation Benefits
88-46 Deposit of CDs Supporting Municipal Bonds
88-55 Insurance Coverage of CDs Purchased in Secondary Market and Sold to Bank Customers
88-57 Recordkeeping Requirements for CDs Purchased by Multi-Tiered Agents or Nominees
88-65 Recordkeeping Requirements for Deposits Supporting Municipal Bond Issues
88-73 Determining Ownership of Escrow Accounts for Purposes of Insurance Coverage
90-4 Non-Appropriated Fund Activities (NAFAs)
90-17 Custodial Accounts: Recordkeeping Requirements
90-34 Selling Participations in "Negotiable" Certificates of Deposit: Recordkeeping Requirements
90-39 Reliance on Commonly Accepted Acronyms to Meet the Disclosure of Fiduciary Relationships Requirement Under § 330.4
90-40 Domestic Brokered Deposits of Foreign Bank Customer Funds: Recordkeeping Requirements
90-41 Insurance of Mortgage Servicing Accounts Under New Rules
91-53 Insurance Coverage Afforded Beneficial Interest Holders in Mortgage Revenue Bonds Issued by a Housing Development Authority
91-62 Practice of Carrying Mortgage Servicing Accounts on Depository Institution's General Ledger is Acceptable So Long as Certain Recordkeeping and Reporting Requirements are Met
91-91 Insurance Coverage Provided for Funds Held by a Depository Institution on Behalf of Company Offering a Consumer Rebate/Annuity Program and Participants Therein
92-30 Insurance Coverage of Interest on Lawyer Trust Accounts (IOLTAs)
92-49 Bank's Three-Part Recordkeeping System for Deposit Accounts Satisfies Signature Card Requirements for Joint Ownership Accounts Under 12 C.F.R. § 330.7
94-19 Revocable Trust Accounts Where Named Beneficiary Also Holds Power of Attorney With Respect to the Account
94-20 Titling Requirements for Payable-on-Death Accounts
95-7 Deposit Insurance Coverage of Pension and Profit Sharing Plans
99-6 Obligations Under the "Interagency Policy Statement on Retail Sales of Nondeposit Products" and the FDIC's Recordkeeping and Disclosure Requirements

Reports and Public Disclosure Of Indebtedness Of Executive Officers and Principal Shareholders To A State Nonmember Bank and Its Correspondent Banks

Letter No.
79-5 Opinion Regarding Title VIII Implications on Correspondent Bank Relationship
79-17 Preferential Loans on Bank Stocks Involving Correspondent Banks
79-18 Preferential Bank Stock Loans in Correspondent Relationships
80-3 Reporting Requirements under Titles VIII and IX of FIRA Relating to Overdrafts
81-9 Reporting Requirements of Foreign Banks under FIRIRCA

Securities Activities

Letter No.
83-9 Letter of Credit Issued to Insurance Company Not in Violation of Part 332
83-21 Insured Nonmember Bank May Participate in Investment Services Program Without Violating the Glass-Steagall Act
84-7 Bank Compliance with Regulations on Collecting and Reporting Information on Principal Shareholders
84-18 Nonbank Activities of Nonmember Bank
85-3 Affiliation of Insured Nonmember Banks with Securities and Companies
85-12 Registered Broker-Dealer as Affiliate of Insured Bank
85-21 Nondiscretionary Advances to a Unit Investment Trust by Insured Nonmember Bank Serving as Trustee
85-22 Applicability of 12 CFR 337.4 to Foreign Company Affiliates Engaged in Securities Activities Solely Outside the United States
85-23 Federal Insurance for Deposit-Taking Activities of Trust Companies
86-2 Bank Subsidiary Engaged Only in Securities Activities Permissible for the Bank itself Under Glass-Steagall Act Is Not Required to Meet Definition of a Bona Fide Subsidiary
86-3 Insurance Coverage of Deposits of Futures Commission Merchants and Clearing Organizations in FDIC-Insured Banks
86-5 Acquisition and Resale of Mandatorily Convertible Capital Notes
86-9 Applicability of FDIC Restrictions on Affiliate Engaged in Securities Activities Permissible Under the Glass-Steagall Act
86-18 Glass-Steagall Act Does Not Bar Insured Nonmember Bank Participation as Correspondent in Securities Brokerage and Investment Advisory Services Offered by Others
86-19 Standby Letter of Credit Issued in Lieu of Contractors' Performance Bonds
86-27 Exemption from Securities Activities Prohibitions
86-32 Contract to Provide Securities Brokerage Services at Branch Offices of Participating Financial Institutions
86-36 Sale of Securities and Mutual Funds on Bank Premises
87-4 Application for Deposit Insurance
87-13 Brokerage Services on Premises of State-Chartered Banks
87-14 Sharing a Common Name by Bank and Its Affiliates
87-26 Treatment and Deposit Insurance Application in Light of Competitive Equality Banking Act of 1987
87-34 Thrift Institution—Bank Space/Lease Compensation Agreement with Company Marketing Life Insurance and Fixed Annuity Products
87-50 Application of CEBA Grandfather Provision on Thrift and Loan Affiliated with Mortgage Banking Company and Securities Broker-Dealer
87-52 Computation of Affiliates' "Covered Transactions" under Section 23A
87-56 Taking Collateral for Loan Transfers Risk from Affiliates to Bank
88-2 FDIC Insurance of Accounts of Proposed Industrial Loan Company
88-17 Application of CEBA to Securities Activities Conducted by a Subsidiary
88-24 "Continuous Operation" Provision of 12 CFR 337.4
88-31 Subsidiary Requirements for Broker/Dealer Subsidiary Engaged in Riskless Principal Transactions in U.S. Government Securities, Municipal Bonds and Revenue Bonds
88-36 Bank's Purchase of Mortgage Servicing Rights from Affiliate
88-39 Bank Transactions with Affiliated Securities Companies
88-42 Disclosure Requirement for Bank Securities Activities
88-43 Unrelated Third Party Non-Banking Activities on Insured Nonmember Bank Premises
88-50 Purchase of Low Quality Assets in Credit Card System
88-58 Instances When Securities Subsidiary Must Meet Definition of "Bona Fide" Subsidiary
88-61 Collateral Requirement of Federal Reserve Act Section 23A on Loans to Unaffiliated Third Party
88-75 Insurance Coverage of Mortgage Servicing Accounts
89-1 Contractual Activities of Wholly Owned Subsidiary with Registered Broker/Dealer Do Not Constitute Underwriting for the Purposes of the Glass-Steagall Act and 12 CFR 337.4
89-2 Insured Nonmember Bank Participation in Investment Securities Program
89-4 FDIC Insured Bank Acting for Purchase of Shares of 12b-1 Mutual Funds
89-14 Capital Notes Sold as Unregistered Securities
89-15 12 C.F.R. Part 335—Insider Trading—Employee Savings Plan
89-35 Securities Repurchase Agreement
89-43 Stockholder Rights Plans: Acceleration of Registration of Rights
90-10 Pledge of Government Securities for the Purpose of Securing Bank Deposits In Excess of $100,000
90-58 Insurability of Unit Investment Trusts
90-67 Sublease of Office Space in Bank Branch to Securities Broker-Dealer Does Not Violate Glass-Steagall Act
90-69 Bank's Open Market Purchase of Subordinated Debt Issued by Its Parent Holding Company Is Subject to Lending Limits of § 23A of the Federal Reserve Act
91-32 Sale of Annuities by Bank as Agent for Insurance Company Where Bank Does Not Engage In Any Activities Prohibited by the Glass-Steagall Act Is Permissible
91-36 Whether a Bank Must Be Registered as a Transfer Agent Under Section 17A of the Securities Exchange Act Where Bank Transfers Only Corporate Debt Securities
91-71 Treatment of Securities Purchased by Trade Association Pursuant to Master Repurchase Agreement Between Association and Bank Upon Subsequent Failure of Bank
91-74 Prior Notice Provision of 12 C.F.R. § 337.4 Applies Where Insured Nonmember Bank Establishes Subsidiary and Transfers Its Investment Portfolio to Subsidiary
92-28 Effect of Section 24 of the FDI Act on State-Chartered BIF Member Insured Savings Bank's Investment in Limited Partnership Organized to Make Portfolio Investments in Equity of Various Enterprises
92-48 Insured Nonmember Bank May Participate in Brokerage Networking Program Without Violating Glass-Steagall Act
92-57 Explanation of 12 C.F.R. Part 344 (Recordkeeping and Confirmation Requirements for Securities Transactions)
93-12 Mutual Fund Investments Permissible for Insured State Banks
93-26 FDIC Will not Require Compliance with New SEC Rule 16b-3 Until September 30, 1993 or Later Effective Date Established by SEC
93-33 FDIC Will Not Require Compliance with New SEC Rule 16b-3 Until SEC Sets Final Effective Date
93-51 12 U.S.C. § 1831a Does Not Prohibit State-Chartered Banks from Purchasing Nominal Amounts of Farmer Mac Common Stock as Necessary to Participate in Farmer Mac Program
93-60 Proportionate Anti-Dilution Adjustments and Amendments to Non-Qualified Stock Option Plans Do Not Require Shareholder Approval Under FDIC Regulations
94-6 Whether Bank Subsidiary May Hold Common Stock Listed on National Securities Exchange
94-30 Application of § 344.4(a)(2) Which Establishes Recordkeeping and Confirmation Requirements for Securities Transactions
94-33 Guidance Concerning the Retail Sale of Mutual Funds and Other Non-Deposit Investment Products Through a Securities Brokerage Service
94-53 Application of Section 344.4: Sale of Securities Through Banks
95-30 State Banks May Hold the Stock of a Company Which Operates an EFT System of Which They Are Members
95-37 Whether Post-trade Confirmation and Matching Messages Transmitted Through an Electronic Trade Confirmation System Meet the Requirements of FDIC Part 344
96-1 Interpretation of the Department of Treasury Regulations Implementing the Government Securities Act
98-1 Interpretation of General Counsel Opinion Number 6
00-1 Whether a state nonmember bank may use FHLMC and FNMA mortgage pass-through securities as the underlying security for repurchase agreements the bank issues to customers


Letter No.
87-8 Deposit Insurance Coverage of Usufruct Accounts in Louisiana
87-29 Irrevocable Trusts and Usufructs


Letter No.
81-7 Interest Rates for Loans Made to Out-of-State Bank Customer
83-16 Interest Rate on Loans to Customers Residing in States That Have Rejected the Federal Preemption Provision
88-45 Relationship of State Usury Preemption Laws

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