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#20765 - 06/13/02 09:41 PM Question on different bank structures
stevebuc Offline
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Joined: Jun 2002
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I am doing some research and would like to know if anyone could the different banking structures i.e. bank and trust, savings and loan. Also what would be the benefit or drawback of creating an institution under the state charter, national charter, thrift charter or member of the Federal Reserve. Your response will be greatly appreciated

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General Discussion
#20766 - 06/14/02 02:30 AM Re: Question on different bank structures
Richard Insley Offline
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Richard Insley
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Toano, VA
Over the years lots of federal and state legislation has "leveled the playing field" considerably between commercial banks and savings institutions.
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#20767 - 06/14/02 04:16 PM Re: Question on different bank structures
Andy_Z Offline
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You may find some info in a recent speech by OCC Comptroller Hawk.
http://www.occ.treas.gov/ftp/release/2002-40a.txt
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#20768 - 06/14/02 05:18 PM Re: Question on different bank structures
downstown Offline
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Joined: Aug 2001
Posts: 295
St. Louis, MO
One item to consider with a thrift charter is that thrifts are not currently exempt from the Investment Advisers Act of 1940, as are national and state chartered banks. Therefore, if a thrift offers investment adisory services such as trust business, it must register with the SEC (or state depending on assets under management) as an investment adviser. This may cause many financial and regulatory burdens.

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#20769 - 06/17/02 02:31 PM Re: Question on different bank structures
Michelle D Offline
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Michelle D
Joined: Oct 2001
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Terminator Country
Ron, In May 2001, the SEC issued rules that stated savings and loans are now treated as banks under for purposes of the Securities and Exchange Act - this was part of GLBA. The OTS just issued proposed rules on June 13 covering the implemenation of this change. The proposal is available on their website.

The bigger issue is that the SEC is thinking about revoking these exemptions from all "banks" - the banking agencies are lobbying hard to keep the exemptions.
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#20770 - 06/17/02 03:12 PM Re: Question on different bank structures
downstown Offline
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Joined: Aug 2001
Posts: 295
St. Louis, MO
Michelle, Thanks. I have seen the OTS' proposed rules and am still trying to ingest them. Although GLB did level the playing field somewhat between banks and thrifts, there are still some inequities that most people outside the thrift world probably do not realize exist.
Also lets hope that the SEC and banking industry can reach a workable compromise regarding the broker/dealer exemptions.

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