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4000 - Advisory Opinions

Moratorium on Conversion Transactions Imposed by Provisions of FIRREA


November 8, 1989

Douglas H. Jones, Deputy General Counsel

In response to your October 26 letter, we agree with your assessment that neither the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 ("FIRREA") nor any other current provision of Federal law would compel a Savings Association Insurance Fund ("SAIF") member savings association that converts to a bank charter during the moratorium on conversion transactions imposed by the provisions of FIRREA, but remains a SAIF member, to change its status to a Bank Insurance Fund member after the moratorium expires.

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