In Regulation U, section 221.2(1) defines a "Bank" as having the same meaning as 15 USC 78c(a)(6). That definition includes "a banking instution organized under the laws of the US or a Federal savings association, as defined in 1462(5) of Title 12,"

However, 221.2(2) of Reg. U specifically excludes "Any savings and loan association" from the definition of a Bank. What is the definition of a "Savings and loan assocaition" for purposes of 221.2(2)?

To ask it another way, if I am a Federally chartered Savings Association (Regulated by OCC), am I a Bank under Reg. U, or am I a "savings and loan association" that is exempt? (Thus, impacting whether I need to provide a U-1 or G-3 Statement of Purpose)

Thanks

As far as I can tell, when Reg G was merged with U, that reference to 15 USC 78c(a)(6) that seems to conflict with Reg U itself was left there, with the conflict.

The S&Ls - unless someone can point out some obscure change I have missed over the years - use form G-3 and must register once lending exceeds a threshold using form G-1.

Post merger of Reg G with U, I can tell you that I was working at a very large financial company where we had a large national bank and also some FSB affiliates. When the regulators pointed out the need for the G-3 and for registration for the securities lending of the FSBs all of the compliance folks (me included) and lawyers looked at each other and said "who knew?".

We had to do some quick gathering of info to register and use the G-3 going forward for loans in the FSBs.

The G-1 form states: Who must file: Section 221.3(b)(1) of Federal Reserve Regulation U requires that FR Form G-1 be completed by every person (other than commercial banks, brokers, or dealers) who during any calendar quarter extends a total of $200,000 or more, or has outstanding a total of $500,000 or more, in credit secured directly or indirectly, in whole or in part, by collateral that includes any margin stock.