tailieunhanh - Interim Final Rule, Savings and Loan Holding Companies 76 Fed. Reg. 56508-56606 (Sept. 13, 2011)

In this paper, we utilize a long and wide panel of more than 300 banks – the data are taken from BankScope – for the years 1994–2008 from 19 European countries to make a long&term comparison of the performance of the banks across different organizational structures. As performance measures we use profitability, cost efficiency and loan losses. To fully capture the possible impact of the ownership diversity, we make two refinements: i) we re&code several banks; ii) we provide a finer classification of the banks’ organizational structure by splitting each group into two more groups: the commercial banks as retail vs. non&retail, the cooperative banks as tightly vs. loosely federated, and the savings banks as privately vs. government owned. . | _ American Bankers Association Building Success. Together. C. Dawn Causey 202 663-5434 dcausey@ November 7 2011 Jennifer J. Johnson Secretary Board of Governors of the Federal Reserve System 20th Street Constitution Ave. NW Washington DC 20551 Re Interim Final Rule Savings and Loan Holding Companies 76 Fed. Reg. 56508-56606 Sept. 13 2011 Dear Ms. Johnson The American Bankers Association ABA welcomes the opportunity to comment on the Board of Governors of the Federal Reserve System Board interim final rule addressing a number of transition rules including new Regulations LL and MM for savings and loan holding companies SLHCs including capital adequacy assessments. This comment letter focuses on Regulation MM mutual holding companies MHCs a separate letter addresses Regulation LL. ABA represents banks of all sizes and charters and is the voice for the nation s trillion banking industry and its 2 million employees. Institutions directly affected by the proposal are strongly represented in ABA s membership and participated in the development of this comment letter. The interim final rule transfers the regulation of MHCs to the Board s regulatory framework and attempts to preserve those items of statutory difference between the Home Owners Loan Act HOLA and the Bank Holding Company Act BHCA . It is a difficult task and we commend the Board s efforts. ABA notes that the transfer and supervision of MHCs will provide opportunities for greater understanding as the Board and the mutual industry learn from each other. During this learning period ABA urges the Board to exercise supervisory discretion while systems and expectations are harmonized. As noted in conversations with Board staff the industry and the Board are both learning as the process evolves. Mutuality Mutual savings banks are some of the oldest savings institutions in the country dating back to the early 1800s1. They capitalized on the antipathy toward the earlier banks due to among other issues the