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4000 - Advisory Opinions

Conversion Transactions: Institution Resulting From The Merger of Two Affiliates


February 23, 1990

Douglas H. Jones, Deputy General Counsel

In response to your January 22 letter, we raise no legal objection to your conclusion that, upon the merger of * * * , * * *  [Bank A] * * *  into its affiliate, * * *  [Bank B]

* * *  under the facts set forth in your letter, paragraph (i) of section 5(d)(2)(D) of the Federal Deposit Insurance Act would be properly applied to [Bank B] taking into account [Bank A's] total deposits as of May 1, 1989, as well as [Bank B's] total deposits as of that date. As your letter points out, this conclusion simply treats the institution resulting from the merger of two affiliates, both of which were in existence and operating on May 1, 1989, as having the same capacity under section 5(d)(2)(C) and (D) to acquire deposits from a member of the Savings Association Insurance Fund as the two merging institutions would have had individually had they not merged.

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