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Federal R eserve Bank
OF DALLAS
W ILL IA M

H. W ALLACE

DALLAS, TEXAS 75222

FIRST V IC E PR E S ID E N T
AND C H IE F O PER ATING O FFICER

April 25, 1989
Circular 89-29

TO:

The Chief Executive Officer of all
member banks and others concerned in
the Eleventh Federal Reserve District
SUBJECT

Transactions Between T h r ift In s titu tio n Subsidiaries o f Bank Holding
Companies and Other Holding Company Subsidiaries (Docket Number R-0663)
DETAILS

The Federal Reserve Board has requested public comment on whether
certain conditions restricting transactions between thrift insitutions
acquired by bank holding companies and other holding company subsidiaries,
commonly referred to as the "tandem operations restrictions," should be
retained, modified, or removed.
Comment is requested by May 19, 1989.
The Board has, since 1982, imposed these conditions by order on the
acquisition and operation of thrift institutions by bank holding companies.
The Board recently received a request for relief from the tandem operations
restrictions from Citicorp, a bank holding company which operates several
thrift institution subsidiaries.
Comments should be addressed to William W. Wiles, Secretary, Board of
Governors of the Federal Reserve System, Washington, D.C. 20551. All
correspondence should refer to Docket No. R-0663 and must be received by May
19, 1989.
ATTACHMENTS

The Board's notice is attached.
MORE INFORMATION

For further information regarding this circular, please contact Dean
Pankonien at (214) 651-6228. For additional copies of this circular, please
contact the Public Affairs Department at (214) 651-6289.
Sincerely yours,

For additional copies of any c ircula r please c on tact the Public A ffa irs Department at (214) 651-6289. Banks and others are
encouraged to use the fo llow ing incom ing WATS numbers in con ta c tin g th is Bank (800) 442-7140 (intrastate) and (800)
527-9200 (interstate).

This publication was digitized and made available by the Federal Reserve Bank of Dallas' Historical Library (FedHistory@dal.frb.org)

FEDERAL RESERVE SYSTEM
CITICORP
New York, New York
Notice Requesting Relief from Conditions Imposed on the
Acquisition of Thrift Institutions by Bank Holding Companies
C itic orp,
notice
B oard

requ es ti ng
by order,

Company

A ct

t r a n s ac ti on s
and

their

c o m m o nl y
pr ov id e

U.S.C.

of

22 5. 23 (a )( 3) ),

relief

pursuant

(12

225 .23 (a) (3)

N e w York,

the

on

among,

h ol d i n g
referred

N ew York

from

r e s t r i c ti o ns

to s ec t io n 4(c)(8)
§ 1843(c)(8))

B oa r d ' s

joint

of

imposed

(12

o p er a t i o n s

filed
by

a

the

the Bank H ol di ng

Act")
Y

has

and

sect io n

C.F.R.

between,

and

ins ti t ut i on s u b s i d i a r i e s of C i t i c o r p

c om pa ny
as

("BHC

Regulation

marketing

thrift

to

the

("Citicorp"),

the

a f fi li at es .
"tandem

T hese

o p e r at i on s

conditions,
r es tr ic t io n s, "

that:

(1)
the t hrift i n st i tu t io n s would be o pe ra te d as
separate,
independent,
profit-oriented
corp or at e
e n t i ti es and would not be o pe r at e d in t an de m with any
other s ub si d i a r y of the bank h ol di ng company.
In
order to c arry out this condition, the bank h ol ding
c o mp a n y and thrift ins ti tu t io n s would l imit their
o p e r a t i o n s so that:
(a)
no b anking or other s u bs i d i a r y of the bank
ho ld in g co mp an y would link its d e p o s i t - t a k i n g
a c t i v i t i e s to a ccoun ts at the thrift inst it ut io ns
in a s weeping a r r a n g e m e n t or similar arrangement;
and,
(b)
the thrift ins ti tu t io n s would not d i r e c t l y or
i n d i re ct ly so li c it d e p o s i t s or loans for any other
s u b s i d i a r y of the bank h ol d in g c o mp a n y and the bank
h o ld i n g co mp an y and its s u b s i d ia r ie s would not
s o li c i t d e p o si ts or loans for the thrift
i nstitutions; and,
(2)
to the e xt en t n e c e ss a ry to insure i n de pe nd en t
o p e r a t i o n of the thrift i n s ti t ut i on and p r ev e n t the
improper d i v e r s i o n of funds, the thrift ins ti tu ti on s
would not engage in any t r an s ac t io n s with the bank
h o ld in g c om p a n y or its other s u bs i d i a r i e s w it h ou t
prior approval of the a pp ro p ri a te F e de ra l R es er ve Bank.
Citicorp
normal

and

lawful

c on te nd s
b usiness

that

these

behavior,

c o n d it i on s

impose

p ro h ib i t

unnecessary

costs

and

burdensome

fr us tr at e

efforts

i n s t i tu ti on s
the

tandem

deterrent
a

time

to

to

to

thrift
bank

provisions

of

bank

and

the

restrictions

23B of

on

area,

it

believes

appropriate

or

significant

public

participation

development

of

conditions.

p ub li c

the

comment

modified

or

on

No.

Governors

be

m ai le d

no

delivered

later

the

N.W.,

D.C.,

Citicorp's

r equest
of

Boari
12,

this

be

than

its h ol d in g
23A

r eq ui re d
a c ti o n

and

by law.
in this

in light of

surrounded

"C"

b et w e e n
for

the B oa rd
of

notice,

rec ei ve d

at

May

1989.

System,

courtyard

between

W as hi n g t o n ,

April

must

Reserve

to

the o f f i c e s

w i th o u t

s e ct i o n s

comment,

restrictions

the

authorize

t hrift and

Accordingly,

19,

to W i l l i a m W. Wiles,

Federal

Street,

r eg a r d i n g

R-0663,

of

the

the

that

and

to

institutions

in c o n s i d e r i n g

the

Reform,

w ould

under

at

the

the

original

B oard

should

be

the

s ee ks

retained,

removed.

Comments
Docket

w he t h e r

the

public

f ul fill

p oi nt s

as o t h e r w i s e

that,

to seek

to

f in a nc i al

w hi ch

that

c o mp an ie s,

Institutions

thri ft

req ui r ed

R es er ve Act,

B oard

is

as

help

Citicorp

between

thrift

as a s i g n i f i c a n t

outside

1989,

ac q ui r e

except

the F e d e r a l
The

to

of

transactions

affiliates

for

and

also argues

h o ld i n g

could

Financial

Act

failing

work ed

bank

additi on ,

proposed

to cons um er s,

Citicorp

by

need

In

companies

or

have

companies

Enforcement

h ol d i n g

c o mp a n y

restrictions

critical

r esources .

Recovery

failed

acquisitions

managerial

s er v ic e s

v i a bi l it y .

ho ld in g

i n d u s t r y ’s

limit

restore

fin an ci al

operations

when

t hrift

i n e ff ic ie nc ie s,

w hich

the o f f i c e s

Secre ta ry ,

All

S tr ee t
8:45

relief

the Board
should

20551,

B u il di ng ,

and C o n s t i t u t i o n A ve nue,
a.m.

is

and

5:15

available

to

of G o v e r n o r s

D.C.

E c cl e s

of

refer

comments

B o a rd

Washington,
e ntra nc e,

s hould

p.m.

for

or
20th
N.W.,

w ee kd a ys .

i ns pe c ti o n

at

of G o v e r n o r s .

Governors

of

the

Federal

R es er ve

1989.

(sianed)

Jennifer J. Johnson

J e n n i f e r J. J o h n s o n
A s s o c i a t e S e c r e t a r y of the B o a r d

of

System,