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s i s' -y
Federal R eserve
N

e w

Y

o r k

Ba n k of
, N.Y.

AREA CODE 2 1 2

N ew Y o r k

10045

RE 2 - 5 7 0 0

May 14, 19&5

To the State Member Banks in the Second Federal
Reserve District Subject to Regulation F:

On the reverse side of this letter is a copy of an interpretation,
issued by the Board of Governors of the Federal Reserve System, of the defi­
nition of the term "officer" in section 206.2(o) of Regulation F.

This

interpretation will be published shortly in the Federal Register and Federal
Reserve Bulletin, but it is being sent to you now so that you may have
prompt notice of its content.




ALFRED HAYES,
President.

(Over)

BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM

Interpretation of Definition of "Officer"
for Regulation F Purposes
Section 206.2(o) of Federal Reserve Regulation F defines
the terra "officer" to mean any person who occupies one or more of
certain enumerated positions in a member State bank "and any other
person who participates in major policy-making functions of the bank."
Among the positions so enumerated is that of "Vice President", but
it is also provided that a person bearing the title of "Vice President"
who does not "participate in major policy-making functions of the
bank" is not an officer for the purposes of Regulation F.
When Regulation F was adopted, an accompanying description
in the Federal Register (30 F.R.

362; January 12, 1965) stated that

"an ’officer1 of a bank is defined to exclude persons who, regardless
of title, do not participate in major policy-making functions."

This

statement has resulted in some confusion as to the scope of the
definition of "officer".

In order to clarify the matter, the Board

of Governors has made the following interpretation.
All persons holding any position enumerated in section 206.2(o),
except those holding a position as "Vice President", are officers

for

purposes of Regulation F regardless of whether they participate in
major policy-making functions.

The second sentence of section 206.2(o),

which provides that certain persons are not officers if they do not
participate in major policy-making functions, applies only to persons
with the title of "Vice President".