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Board Interpretations of Regulation O

3-1035

“EXECUTIVE OFFICER”—Members of Boards of Managers and Finance Committees of Trust Companies

This refers to your letter of March 3, 1936, submitting an inquiry from the
, Trust Company,
and an opinion of counsel for your bank as to whether members of the boards of managers of branches of the trust company, chairmen of the boards of managers of branches of the trust company, and members of the finance committees of such branches are “executive officers” within the meaning of that term as defined in section 1(b) of the Board’s Regulation O.
It appears from the information submitted that the members of the board of managers of a branch of the trust company are chosen by the board of directors of the trust company; that such members give no regular time to the business of the bank other than attendance at meetings of the board; that the individual member of the board has no powers in the management of the branch other than his vote as a member of the board of managers and has no compensation other than fees for attendance at meetings; and that the board of managers elects branch officers, passes on loans of limited amount, and acts as a board of directors of the branch, but with every act subject to the approval and control of the board of directors of the trust company. While it is clear that such members are not strictly directors, since they are not elected by the stockholders, it is apparent that their duties are analogous to the functions usually exercised by a board of directors of a bank and, on the basis of the facts stated above, it is the view of the Board that the members involved are not included within the definition of the term “executive officer” as contained in the Board’s Regulation O.
The chairman of the board of managers of a branch would not be considered an “executive officer” unless he “participates in the management of the bank or any branch thereof” within the meaning of that phrase as used in section 1(b) of Regulation O, and the determination of this question must be based upon the facts in each case. It appears from the bylaws of the trust company that the chairman of the board of managers of a branch is appointed by the board of managers subject to the approval of the board of directors of the trust company, and that such chairman is only authorized to preside at meetings of the board at which he may be present. It is stated in the letter from the trust company that the only duties of a chairman are to preside at meetings of the board of managers. It is also understood that there are two chairmen of boards of managers of branches of the trust company who are paid a small salary in lieu of a fee for attendance at meetings. These salaries are reported as being $250.00 and $528.00 per annum. Although the payment of a salary may in some cases indicate that the recipient has duties to perform in an individual capacity which would bring him within the classification of an “executive officer,” it is the Board’s understanding that the chairmen involved perform no other duties than to preside at meetings of the boards of managers. Therefore, on this basis, it is the opinion of the Board that such chairmen are not included within the meaning of the term “executive officer” as contained in the Board’s Regulation O.
In connection with members of the finance committees of such branches, it appears that such committees are appointed by the boards of managers pursuant to the general authority of the bylaws of the trust company and that the functions of such committees are similar to the functions of the executive committee of the trust company, such as passing upon loans in a preliminary way between meetings of the boards of managers. Assuming that the members of such committees exercise no other duties in the management of the bank or branch except those of attending committee meetings and voting upon matters considered at such meetings, it is the Board’s view that such members are not executive officers within the meaning of the Board’s Regulation O.
The conclusions reached above are limited to those persons whose only duties are to serve in the capacities referred to above, and who hold no other office in the trust company or any branch thereof. X-9576; May 4, 1936.
3-1036

“EXECUTIVE OFFICER”—Indebtedness at Appointment

The prohibitions of section 22(g) of the Federal Reserve Act refer to an executive officer of a member bank who is an executive officer thereof at the time he borrows from or otherwise becomes indebted to the bank. Accordingly, when a loan is made in good faith by a member bank to an individual who is not at the time of the making of the loan an executive officer thereof and the loan is not made in contemplation of his becoming an executive officer of the bank, there is nothing in the statute which would prohibit such person from subsequently becoming an executive officer of the bank, notwithstanding his outstanding indebtedness thereto. Digest of 1936 Fed. Res. Bull. 121.
3-1037

“EXECUTIVE OFFICER”—Secretary of Board of Directors

The secretary of the board of directors of a member bank who is also a director and whose functions are those pertaining to the minutes of the board and the certification of resolutions passed by the board and who does not in any sense participate in the management of the bank is not an “executive officer” as defined in Regulation O. Digest of 1936 Fed. Res. Bull. 248.
3-1038

“EXECUTIVE OFFICER”—Resolutions for Inactive Officers

Form of Resolution of Board of Directors with Respect to Inactive Officers
The definition of the term “executive officer” as amended effective July 1, 1939, provides that it will be assumed that certain officers of a member bank are executive officers “unless it is provided by resolution of the board of directors or the bank’s by-laws that any such officer is not authorized to participate in the operating management of the bank and he does not actually participate therein.” There are printed below two forms of resolutions which comply with this provision of the definition and which could be adopted by the board of directors of a member bank which desires to make loans to an officer who does not actually participate in the operating management of the bank. These forms are merely illustrative of the type of resolution contemplated by the amended definition. No particular form of resolution or provision of the bylaws is required, however, and any form which provides that the officer in question is not authorized to participate in the operating management of the bank is sufficient for the purposes of the amended definition.
Form No. 1
Whereas, for the purposes of Regulation O of the Board of Governors of the Federal Reserve System, an officer is not regarded as an executive officer if it is provided by resolution of the board of directors that he is not authorized to participate in the operating management of the bank and he does not actually participate therein; and
Whereas, the office of
held by Mr.
in this bank is an honorary position;
Now, therefore, be it resolved, That the incumbent of the said position shall not be authorized to participate in the operating management of the bank.
NOTE: If the officer in question is also a director of the bank, there should be added to the last paragraph of the above resolution the words “otherwise than in the capacity of a director of the bank.”
NOTE: The first paragraph of the above resolution may be omitted if desired. The word “inactive” may be used in place of “honorary” if desired.
Form No. 2
Resolved, That no vice presidents of this bank other than Messrs.
,
,
and
shall have authority to participate in the operating management of the bank.
NOTE: If the officer affected is also a director of the bank, there should be added to the above resolution the words “otherwise than in the capacity of a director of the bank.”
NOTE: If desired, the first paragraph of form No. 1 may be used in connection with form No. 2.
1939 Fed. Res. Bull. 636, 637.
3-1039

“EXECUTIVE OFFICER”—Inactive Discount Committee Member

This refers to your letter of March 25, 1940, and previous correspondence regarding the status of Mr.
, vice president and director of The
National Bank, of
, under the Board’s Regulation O.
The board of directors of the bank in July, 1939, adopted a resolution to the effect that Mr.
is not authorized to participate in the operating management of the bank. A question was raised by the examiner concerning his status, however, because of the fact that he was also serving as a member of the discount committee, which, under the bylaws, consisted of the “president, cashier, and three directors”. It appears from your letter of March 25, quoting a letter received from the cashier of the bank that Mr.
has now resigned his position on the discount committee and is no longer a member of the committee. While it is understood that he is a member of the examining committee, it is assumed that the duties of this committee are not such that members thereof are to be considered as participating in the operating management of the bank by reason of such membership.
Since Mr.
is no longer a member of the discount committee, it is not necessary for the Board to express any opinion with regard to the question which was raised by reason of such membership. It is understood that under the resolution adopted by the board of directors Mr.
is not authorized to participate in the operating management of the bank and that he does not actually participate therein. In the circumstances, he is not an executive officer within the meaning of Regulation O.
While it appears that president
with respect to whom a like resolution was adopted by the board of directors, is a member of the discount committee, it is not understood that he is borrowing from the bank or that any question regarding his status has been raised at this time. S-210; April 10, 1940.
3-1040

“EXECUTIVE OFFICER”—Discount Committee Member

The Board has been requested to render an opinion on the question whether an officer of a member bank, who is also serving as a director and as a member of the discount committee of the bank, is to be regarded as an executive officer within the meaning of the Board’s Regulation O, as amended effective July 1, 1939, notwithstanding the adoption of a resolution by the board of directors providing that he is not authorized to participate in its operating management.
The Board of Governors has considered this question in the light of the definition of the term “executive officer” in its Regulation O, the views expressed by Federal Reserve Banks and others who have considered this matter, and the authority of the Board to define the term “executive officer.” The Board has concluded that an officer of a member bank, who is also serving as a director and as a member of the discount committee and with respect to whom a resolution as described above has been adopted by the board of directors, is to be considered an executive officer within the meaning of Regulation O except in a case where a provision of the by-laws of the bank or a resolution of the board of directors requires the service in rotation of every director as a member of the discount committee and the directors do in fact serve as members of the committee in accordance with such by-law or resolution. 1941 Fed. Res. Bull. 1087.
3-1041

“EXECUTIVE OFFICER”—Inactive Officer Serving on Discount Committee

The Board has been requested to render an opinion with regard to the application of Regulation O to inactive officers of smaller member banks who are also directors and serve as members of the discount committee.
As stated in a ruling by the Board published at page 1087 of the 1941 Federal Reserve Bulletin, a person who is an inactive officer and director of a member bank and with respect to whom a resolution has been adopted by the board of directors providing that he is not authorized to participate in the operating management of the bank will not be considered an executive officer because of his service on the discount committee where the by-laws of the bank or resolution of the board of directors requires the service in rotation of every director as a member of the discount committee and the directors do in fact serve as members of the committee in accordance with such by-laws or resolution. The difficulty was pointed out in applying this principle to small member banks having usually only five directors all of whom are also serving as members of the discount committee.
In the circumstances, the ruling referred to above is hereby extended so that, in addition to the rule enunciated therein, an officer of a member bank with respect to whom a resolution described above has been adopted who is also serving as a director and as a member of the discount committee where all of the members of the board of directors are also members of, and do in fact serve on, the discount committee will not be considered an executive officer within the meaning of Regulation O. 1943 Fed. Res. Bull. 215.
3-1042

“EXECUTIVE OFFICER”—Vice Chairman Authorized to Sign Documents

The Board has received an inquiry as to whether the term “executive officer,” as defined in the Board’s Regulation O, embraces the vice chairman of the board of directors of a member bank who, in the absence of the chairman, serves as a member of the loan and discount committee and who also, in the absence of the chairman, is authorized to execute any and all documents or instruments on behalf of the bank. It is further understood that the member bank has adopted a resolution to the effect that the chairman of the board is not authorized to participate in the operating management of the bank and does not actually so participate otherwise than in his capacity as director.
Under section 215.1(b) of Regulation O the chairman of the board of directors of a member bank is assumed to be an executive officer unless it is provided by resolution of the board of directors or the bank’s by-laws that he is not authorized to participate in the operating management of the bank and he does not actually participate therein. In view of this provision, although a bank may have adopted such a resolution with respect to the chairman, he must be considered an executive officer if in fact his duties involve participation in the operating management of the bank. Likewise, the vice chairman would be an executive officer if, in the absence of the chairman, he has authority to perform such duties.
It appears from the information supplied that the loan and discount committee, which consists only of members of the board of directors, does not actually make loans but rather reviews loans made by loan officers of the bank and acts in a supervisory and advisory capacity. The Board is of the view that these duties are such as are normally performed by directors, as contrasted with the duties of management, and accordingly would not make either the chairman or the vice chairman an executive officer for the purpose of Regulation O.
However, it is also the view of the Board that the chairman and vice chairman of the member bank do participate in the operating management of the bank because of their authority to execute any and all documents or instruments on behalf of the bank. The Board believes that the broad authority to execute such documents brings both the chairman and the vice chairman within a 1940 unpublished interpretation of the Board to the effect that an inactive vice president of a member bank who was authorized to sign deeds, checks, drafts, and other documents in the absence of the president, but who was expressly denied authority to make loans or to perform any of the other duties of an executive officer, should be considered an executive officer. 1962 Fed. Res. Bull. 289.
3-1043

EXEMPTED TRANSACTIONS—Loans to Corporation Invested in by Executive Officer

Section 22(g) of the Federal Reserve Act does not prohibit a loan by a member bank to a corporation even though an executive officer of such bank is substantially interested in the corporation where such loan is made in good faith and the proceeds would be used by the corporation for its corporate purposes. Digest of 1936 Fed. Res. Bull. 249.
3-1044

EXEMPTED TRANSACTIONS—Life Insurance Plan as Loan

In your Bank’s letter of March 28, 1961, and in subsequent correspondence and discussions, the question was presented as to whether the institution by a member bank of a program of so-called “split-dollar” life insurance for its managerial employees would result in executive officers becoming indebted to the bank in excess of $2,500, which is prohibited by section 22(g) of the Federal Reserve Act and the Board’s Regulation O. In the meantime, the same question has been raised in two other Federal Reserve Districts involving life insurance plans that differ somewhat in detail but are substantially the same as the plan described by you.
It is understood that the member banks are interested in the plan since they believe it will enable them to recruit and retain in their employ promising young men having potential managerial ability. The insurance may be attractive to a young employee since it enables him to secure life insurance at much lower rates than would be otherwise available, and at a time when his need for insurance is perhaps the greatest.
All the various plans of split-dollar insurance which have been examined are based on the fact that in every permanent life insurance contract there is (1) an investment element represented by cash value and dividends, if any, that increases each year, and (2) the insurance element that decreases as the investment element increases.
While, as indicated, different plans may vary in detail, they all appear to incorporate the same basic features. Pursuant to an agreement made with its key employees, a bank takes out a life insurance policy for each. The bank pays that portion of the premium that is equivalent to the increase in the cash surrender value of the policy and the employee pays the remainder. However, since the policy at its inception has no cash surrender value, special arrangements usually are made for payment of the entire first year premium by the employee, although arrangements in this respect vary with different insurance plans. When a policy is paid up, or should the employee die or his services be terminated during the life of the policy, the bank receives a return of an amount equivalent to the sum of the premiums it has paid.
Under some forms of agreement, the employee obligates himself, in the event his employment is terminated during the life of the policy, to pay to the bank any difference there may be between the cash surrender value of the policy and the aggregate premiums therefore paid by the bank with interest compounded at 2 percent per annum. In the unlikely event that no dividends have been paid, it is understood that this could amount to $2,920 in the twenty-fifth year of a $50,000 policy, thus exceeding the $2,500 limitation provided by Regulation O. However, the Board considers the likelihood of this ever happening to be so remote that it may be disregarded for purposes of the question here considered.
Regulation O may be violated whenever, as a result of any transaction, an executive officer becomes indebted to his bank, directly or indirectly. Under no plan of split-dollar insurance that has been brought to the Board’s attention does the executive officer ever become so obligated. On the contrary, the bank must look solely to the cash surrender value of the policy, including dividends, for reimbursement of the sum expended for its portion of the premium. Accordingly, since any obligation to make payment to the bank runs to the insurance company and not to the executive officer, it is the Board’s view that no violation of the regulation would be involved.
Finally, it seems evident from the legislative history of section 22(g) that its underlying purpose was not to interfere with or discourage banks from providing their employees with various forms of fringe benefits, including programs for life insurance. This is not to say, however, that a violation of the regulation would not result if, under the terms and conditions of a particular plan, an executive officer is required to become indebted to his bank in excess of the $2,500 permitted by the Regulation. S-1887, March 28, 1961.
3-1045

PROHIBITED TRANSACTIONS—Loans from Trust Funds

The restrictions contained in section 22(g) of the Federal Reserve Act and in the Board’s Regulation O include loans to executive officers of member banks from trust funds administered by such banks. Likewise, an indebtedness of an executive officer of a member bank to another bank arising out of the lending of trust funds should be reported to the board of directors as provided in Regulation O. It is contrary to the established principle regarding the handling of trust funds for a trustee to have any interest in the funds of a trust which he is administering and such principle is applicable to executive officers of a corporate trustee.
The $2,500 exception contained in this section does not in any manner affect the provision of section 11(k) of the Federal Reserve Act which prohibits a national bank exercising trust powers from lending funds held in trust to any of its officers, directors, or employees; since the provision in section 22(g) can be applied to loans of the bank’s own funds and thus be given full effect even though it is not regarded as repealing the provision of section 11(k) referred to above. Digest of 1936 Fed. Res. Bull. 324.
Modified by the interpretation at 3-1049. Section 11(k) of the Federal Reserve Act has been repealed, but the prohibition can be found at 12 USC 92a(b).
3-1046

PROHIBITED TRANSACTIONS—Indorsement of Partnership Note

The liability to a member bank of an executive officer thereof arising from his indorsement of a note of a partnership in which he has less than a majority interest constitutes a liability falling within the provisions of section 22(g) of the Federal Reserve Act and Regulation O. If the officer is a member of a partnership under an agreement whereby his liability for partnership debts is limited, his individual indorsement of a note of the partnership would clearly increase the extent of his liability. Even in the case of an unlimited partnership, the act of a partner in adding his individual indorsement to a note of the partnership would appear to create a liability distinct from, and in addition to, his liability as a partner arising by operation of law. Digest of 1936 Fed. Res. Bull. 772.
3-1047

PROHIBITED TRANSACTIONS—Commodity Credit Corporation Notes on Cotton

This refers to Mr. Gough’s letter of December 16, 1937, requesting a ruling on the question whether the provisions of section 22(g) of the Federal Reserve Act are applicable to executive officers of member banks who execute Commodity Credit Corporation notes on cotton.
It appears from the enclosures transmitted with Mr. Gough’s letter that a producer of cotton desiring to obtain a loan on cotton on the forms prescribed by the Commodity Credit Corporation may deal directly with any bank or lending agency. The borrower executes a loan agreement which provides that he shall remain liable to the holder of the note for any deficiency only in the event that he does not reduce cotton acreage or production in accordance with the provisions of an agricultural conservation program offered by the Secretary of Agriculture pursuant to certain provisions of law, or has made any misrepresentation in connection with the loan, or in the event of a breach of warranty contained in the loan agreement. It is also provided that any holder of a note may declare it immediately due and payable if the price of cotton goes above a certain stated amount, upon discovery that the maker has made any misrepresentation in connection with the loan, upon any breach of warranty in the loan agreement, upon any failure on the part of the maker to comply with agreements in connection with a conservation program, or upon the filing by the maker of a petition in bankruptcy or for the composition or extension of debts under the Bankruptcy Act. In these circumstances, it appears that there is a contingent liability on the part of the maker of such a note.
The definition of the term “loan” contained in section 1(c) of the Board’s Regulation O includes a contingent liability, and, accordingly, it is the view of the Board that the liability of an executive officer of a member bank as maker of a note on the form prescribed by the Commodity Credit Corporation representing a loan on cotton falls within the provisions of the Board’s Regulation O.
In this connection, it is appropriate to state that the Board was furnished with a copy of a letter written by the assistant attorney general to the United States attorney at
, under date of February 14, 1935, in which the view was stated that there is a contingent liability on the part of the borrower on loans made on Commodity Credit Corporation forms (which, it is understood, were at that time similar to the present forms) and that such liability was sufficient to bring the case within the scope of section 22(g) of the Federal Reserve Act as it then existed. S-64; Jan. 12, 1938.
3-1048

PROHIBITED TRANSACTIONS—Loan to Officer as Trustee of Estate

This refers to your letter of March 19, 1941, enclosing a copy of a letter dated March 15, 1941, from Mr. A., chairman of the board of directors of the
National Bank, to Mr.
, chief national bank examiner, inquiring whether section 22(g) of the Federal Reserve Act would prohibit the
National Bank from making a loan to A as trustee of his father’s estate.
It appears that Mr. A is chairman of the board of directors of the national bank. It also appears that he is trustee of his father’s estate, in which he has a life interest, and that the property of the estate will upon his death vest in his two sons, one of whom is vice president of the national bank. The trust estate consists of property with a value in excess of $100,000 with no indebtedness, the principal item being a business block yielding approximately $7,500 per annum, and the estate may wish to borrow about $15,000, which Mr. A describes as a “gilt-edged” loan and one “that any bank would obviously welcome.”
It will be assumed that under the laws of the State of
a trustee in borrowing on behalf of the trust may sign the instrument in such a way as to avoid any personal liability on the obligation and that the proposed loan would be handled in this way. While the trustee would thus have no personal liability, he would benefit directly from the making of the loan in his capacity as life tenant of the trust estate, which would be obligated on the note. He is interested in the loan both in a representative capacity and in his own right. In this connection, it is noteworthy that the law forbids a member bank to make any loan or “extend credit in any other manner” to an executive officer.
It appears that the principal purpose underlying the enactment of section 22(g) of the Federal Reserve Act was to prevent the exercise of undue influence by executive officers of member banks in obtaining credit from the banks they serve; and, while there is nothing to suggest that any such influence would be used in this particular instance, it is apparent that the case is one of a type in which undue influence may readily be exercised.
In all the circumstances, and particularly in view of the fact that Mr. A is not only trustee but also a beneficiary of the trust estate which would receive the loan, it is the view of the Board that the making of the loan proposed would contravene the intention of Congress and would be inconsistent with the provisions of the statute. S-258; April 2, 1941.
3-1049

PROHIBITED TRANSACTIONS—Loans from Employee Profit-Sharing Trust Fund

The Board of Governors has been requested to consider the question whether the restrictions of section 22(g) of the Federal Reserve Act and the Board’s Regulation O apply to loans made by a member bank to executive officers from funds held in trust by the bank under an employee profit-sharing plan. It is understood that one of the important provisions of the trust arrangement is that a participating employee is extending the privilege of borrowing for worthwhile purposes up to the amount of his vested interest in the trust, and that all officers and employees of the bank may participate in the plan.
The question presented involves the Board’s interpretation in the 1936 Federal Reserve Bulletin at page 324, to the effect that Regulation O applies to loans made to executive officers of member banks from trust funds administered by such banks.
The Board has reviewed its 1936 interpretation in the light of the facts presented, and has concluded that the views then expressed should be modified so as to permit loans of the type described without regard to the limitation imposed by section 22(g) and Regulation O. The underlying purpose of these limitations was to prevent executive officers from exerting improper influence in connection with loans made to them from deposits accepted from the public for prudent investment. The same dangers against which section 22(g) was directed are not present, insofar as the Board can discern, with respect to loans made from the trust fund established under the profit-sharing plan. The privilege of borrowing is extended to any employee who chooses to become a member and makes contributions to the fund. No member is extended any special treatment since each may borrow on the same terms and in an amount not exceeding his particular vested interest. In these circumstances it is difficult to perceive how an executive officer could exert improper influence.
Accordingly, the Board’s 1936 interpretation as to the applicability of Regulation O is modified to the extent indicated above. 1965 Fed. Res. Bull. 1539.
3-1050

REPORTS OF INDEBTEDNESS TO OTHER BANKS—Morris Plan Companies

A Morris Plan company authorized to lend money, to buy and sell bonds or choses in action, to sell its secured or unsecured evidences or certificates of indebtedness and to receive therefor payments in instalments or otherwise is a “bank” within the meaning of the provision of section 22(g) of the Federal Reserve Act which requires an executive officer of a member bank to report to his member bank any indebtedness to “any bank” other than the member bank of which he is an executive officer. Digest of 1936 Fed. Res. Bull., 249.
3-1051

REPORTS OF INDEBTEDNESS TO OTHER BANKS—Discounted Commercial House Notes

Regulation O provides that if an executive officer of a member bank becomes indebted to any bank other than a member bank of which he is an executive officer, he shall make a written report of such indebtedness to his board of directors. Accordingly, when an executive officer gives his note to a commercial house, which later discounts it with another bank, he thereupon becomes indebted to such bank within the meaning of the regulation and such indebtedness is therefore required to be reported. While the executive officer involved will not always know when his obligation has been acquired by another bank, he should make a written report of such indebtedness as soon as he becomes aware of such fact. Digest of 1936 Fed. Res. Bull. 690.
3-1052

REPORTS OF INDEBTEDNESS TO OTHER BANKS—Credit Unions

In view of the above, the Board has concluded that indebtedness of an executive officer of a member bank to a credit union organized under the Federal Credit Union Act of June 26, 1934, need not be reported to the board of directors of the member bank. Selected portion of S-1550; Oct. 8, 1954.
3-1053

REPORTS OF INDEBTEDNESS TO OTHER BANKS—Foreign Bank’s Domestic Branch

* * *A related inquiry received by the Board is whether a branch in this country of a foreign bank, such as the one involved under (a) above, falls within the term “any bank” in the second sentence of section 22(g) of the Federal Reserve Act (12 USC 375a), which requires an executive officer of a member bank to report to that bank any indebtedness owed by him to “any bank” other than the member bank.
The Board is of the view that, for reasons similar to those determinative of the matter set forth in (a) hereof, such a branch clearly is within the words “any bank” in section 22(g) of the act, and that, accordingly, any indebtedness of an executive officer of a member bank to any such branch must be reported as required by the statute.* * * 1964 Fed. Res. Bull. 168.
3-1054

REPORTS OF INDEBTEDNESS TO OTHER BANKS—Private Banks

* * *The Board had received an inquiry related to the matters covered under 3-1053 above. The question is whether a private bank . . . comes within the term “any bank” in the second sentence of section 22(g) of the Federal Reserve Act (12 USC 375a). That statute requires any executive officer of a member bank to report to that bank any indebtedness owed by him to “any bank” other than the member bank.
The Board’s view is that any indebtedness of an executive officer of a member bank to any such private bank must be reported as required by the aforementioned provision of section 22(g) of the Act since . . . the private bank clearly is within the words “any bank” as used in the statute.
These views of the Board supersede any other previous interpretations to the extent that they conflict with these views, and to that extent such interpretations are hereby revoked.* * * 1964 Fed. Res. Bull. 169.
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