Cases: BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM 1990 Fed. Res. Interp. Ltr. LEXIS 350 August 29. 1990 CORE TERMS: subsidiary, revisions, BHC Act, renumbered, sentence, banking, acquire, accurately, revised, deleted REQUESTBY: Robert E. Mannion, Esq. Arnold & Porter 1200 New Hampshire Avenu

ed to be voting securities for purposes of the BHC Act, in the event that a BHC Member (or a group of BHC Members whose Interests are aggregated for BHC Act purposes) acquires an 27 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0042806 CONFIDENTIAL SDNY GM_00188990 EFTA01356762

ed to be voting securities for purposes of the BHC Act, in the event that a BHC Member (or a group of BHC Members whose Interests are aggregated for BHC Act purposes) acquires an 27 EFTA01394924 Interest (or Interests) which would result in such BHC Member (or group of BHC Members) owning an Interest

Capital Contribution, contained herein. EFTA01399426 the Members do not have voting extent that the Interests held by the Members are deemed BHC Act, that portion of the Interest held by a Member that is, or is company, as defined in the BHC Act, or is a non-bank subsidiary of such otherwise s