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#193757 - 05/25/04 02:36 PM Principal shareholder of a holding company
Gary W Offline
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Gary W
Joined: Jun 2003
Posts: 9
Land of Oz
Is a principal shareholder (a human, not a company) of a holding company which is the 100% owner of a bank considered a principal shareholder of the bank also and therefore subject to the reporting and disclosure provisions of Regulation O as it relates to the Bank? I'm a bit confused after reading the definition of a principal shareholder in 12 CFR 215.2.

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#193758 - 05/25/04 02:39 PM Re: Principal shareholder of a holding company
redsfan Offline
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redsfan
Joined: Dec 2000
Posts: 3,455
The Pennant Race
From the definition of a principal shareholder in section 215.2:

(2) A principal shareholder of a member bank does not include a company of which a member bank is a subsidiary.


IMO, there is nothing ambiguous about that statement. Principal shareholders of your parent holding company are not principal shareholders of your bank for purposes of Reg O.
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#193759 - 05/25/04 07:01 PM Re: Principal shareholder of a holding company
Ted Dreyer Offline
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Ted Dreyer
Joined: Apr 2001
Posts: 2,245
A principal shareholder of your holding company is an insider of an affiliate of the bank for Reg O purposes, but not an insider of the bank

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