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District Circular Letters

July 25, 1997

FEDERAL RESERVE ACT--SECTIONS 23A and 23B:
TRANSACTIONS BETWEEN MEMBER BANKS AND SUBSIDIARIES

To Member Banks,
Bank Holding Companies, and Others Concerned
in the Twelfth Federal Reserve District

Proposed Application of Sections 23A and 23B of Federal Reserve Act (Docket R-0977)

The Federal Reserve Board has requested comment on a proposal to apply sections 23A and 23B of the Federal Reserve Act to transactions between a member bank and any subsidiary that engages in activities that are impermissible for the bank itself and that Congress has not previously exempted from coverage by section 23A. Sections 23A and 23B restrict the ability of a member bank to fund an affiliate through direct investment, loans, or other transactions that might expose the member bank to risk.

Comment is requested by September 3, 1997.

The proposed treatment is largely consistent with the existing treatment of these subsidiaries by the other banking agencies, which have applied sections 23A and 23B in some form to transactions between a bank and such subsidiaries.

Copies

Copies of the Board's notices (Docket R-0977) are available from our Corporate Services Department. To request copies to be sent via mail, please call (415) 974-2748. To request copies to be sent via fax, please call (415) 974-3333, and specify document numbers 4162.

Additional Information

For additional information regarding these matters, please contact our Banking Supervision and Regulation Department, at (415) 974-3007.

FEDERAL RESERVE BANK OF SAN FRANCISCO