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Interpretive Letter #1125

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The document is an Interpretive Letter from the Comptroller of the Currency regarding a Tennessee bank's request to reclassify common stock into preferred stock classes under Tennessee corporate law. The letter confirms that the bank can proceed with this reclassification after obtaining OCC approval, citing the need to reduce administrative costs and transform from a reporting to a nonreporting company. It outlines the share reclassification plan, dissenters' rights for shareholders, and compliance with both state and federal regulations.

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What is an interpretive letter?

Interpretive letters provide guidance on the staffs views as to the application of particular FINRA rules under specific circumstances. Members, associated persons, and their counsel should consider seeking further guidance regarding their own unique circumstances.

What is a formal banking relationship?

(Emphasis added.) Account means a formal banking relationship established to provide or engage in services, dealings, or other financial transactions including a deposit account, a transaction or asset account, a credit account, or other extension of credit. 31 C.F.R.

What is a letter from a financial institution?

A bank confirmation letter (BCL) is a letter from a bank or financial institution confirming the existence of a loan or a line of credit that has been extended to a borrower.

What is the OCC interpretive letter 1179 for DLT related activities?

Interpretive Letter #1179 Prior to seeking supervisory non-objection, the bank should consider all applicable laws, ensure that the proposed structure of the activity is consistent with such laws, and that the compliance management system will be sufficient and appropriate to ensure compliance.

What is the meaning of letter of interpretation?

A letter of interpretation provides supplementary guidance that clarifies how to apply to a specific workplace situation a policy or procedure disseminated through the Code of Federal Regulations or the OSHA directive system.