In evaluating a proposal to establish an SLHC under section 10(e) of HOLA, the Board is required to consider the competitive effects of the proposal; the financial and managerial resources and future prospects of the applicant and savings association involved; the convenience and needs of the community to be served, including the record of performance under the Community Reinvestment Act ("CRA"); (7) and the effect of the acquisition on the savings association and the insurance risk to the Deposit Insurance Fund.
Section 10(c)(4) of HOLA, governing SLHC holding company activities, requires the Board to consider whether the performance of a particular activity can reasonably be expected to produce benefits to the public (such as greater convenience, increased competition, or gains in efficiency) that outweigh possible adverse effects of such activity (such as undue concentration of resources or decreased or unfair competition, conflicts of interest, or unsound financial practices).
Panel A: Top 10 Assurbanks (in terms of Total Asset) Assurbanks Name Structure Total Underwrit Type Asset Income ($M) ($M) American Intrnl Grp SLHC
Secretary General of the SLHC
Council, Nasri Khoury, has spared no effort in trying to sell the role of his council and its future usefulness.
We can also create new means for participants to reflect on what they share with us, such as the use of a visual calendar in the SLHC
And there are differences in risk management and in oversight between BHCs and SLHCs
, an we are "still in the learning phase," Gibson said.
He suggested the only recourse for the Fed is to issue a new proposal for insurance-based SLHCs
so that concerns can be addressed.
The Nationwide letter says the company is concerned "that the application of an undifferentiated, bank-centric capital framework to all organizations with a depository institution, without regard to their predominant line of business or their unique set of risks, raises safety and soundness concerns for SLHCs
, makes it increasingly difficult for SLHCs
to serve as a source of financial strength to their depository institution subsidiaries.
Rules proposed by federal regulators in June also include provisions dealing with consolidated oversight of insurance companies which operate SLHCs
He added that "if the SLHC
is to be maintained then some terms and clauses in its document should be either cancelled or amended especially those which give the council the authority to making binding decisions that go against how things are constitutionally carried out in both countries.
1, 2013 for insurance company SLHCs
, the executives argue.
This would seem to expand the ability of multiple SLHCs
to mix banking and commerce to an unlimited degree, a result that the sponsors of this bill may not have intended.