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| Bankers Financial Services takes pride in delivering
service and attention to detail throughout our programs. The following
is an example of our thorough due diligence with regulatory agencies
during the development of the Indexed CD program and the responses
we received back upon review of the program... |
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Washington
Dept. of Financial Institutions Review, May 30, 2003 |
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"As of this date, the State of Washington Dept. of
Financial Institutions-Division of Banks has no objection to banks
selling equity-linked certificates of deposit, and investing in OTC
options contracts as non-speculative risk management tools." |
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Arkansas
State Bank Dept. Review, May 28, 2003 |
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Indexed CD Program Review |
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Colorado
Dept. of Regulator Agencies Review, June 2003 |
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"It is the Division's position that Colorado state
chartered banks, industrial banks, and depository trust companies
have the authority to participate in the index-linked CD program as
described in the materials provided to this office." |
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State of
Idaho Dept. of Finance Review, November 1, 2002 |
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"The Idaho Bank Act is silent on the permissibility
of specific investment instruments. The bank would expect a bank to
perform a satisfactory due diligence assessment of any investment
product or issue." |
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Iowa Division
of Banking Indexed CD Policy Statement, August 2002 |
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Policy Statment and Board Resolution Guidelines from
the Iowa Division of Banking for entering into Indexed CD program
with BFS. |
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Illinois
Office of Banks & Real Estate Review #1, August 5, 2002 |
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Legal Counsel of IL Office of Banks & Real Estate
stated that ..."The Agency does not object to state banks selling
and investing in certificates of deposit offered through the BFS Program..."
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Illinois
Office of Banks and Real Estate Review #2, January 29, 2003
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...the Agency is satisfied that BFS has taken sufficient
steps to address Regulation DD issues related to the CDs. |
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Louisiana
Office of Financial Institutions Review, July 3, 2003 |
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"While the Louisiana Banking Law is silent with respent
to equity-linked certificates of deposits, LSA-R.S. 6:242(A)(1) states
that a state bank may "receive any pay out deposits, with or without
interest..." |
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Maine Dept.
of Professional & Financial Regulation Review, June 5, 2003
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Indexed CD Program Review |
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State of
Mississippi Dept. of Banking & Consumer Finance Review, June 3, 2003
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Indexed CD Program Review |
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Kansas Office
of the State Bank Commissioner Review, June 30, 2003 |
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"First, it is our opinion that Kansas state-chartered
banks are authorized to sell these types of equity-linked certificates
of deposits ("CD"), pursuant to the general authority given to banks
in K.S.A. 9-1101, as amended, to receive deposits and pay interest
on deposits." |
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Missouri
Division of Finance Review, August 1, 2002 |
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The Acting Commissioner of the Missouri Division of
Finance has stated that ..."Indexed CD's are a permissible product
offering for Missouri state-chartered banks." |
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Nebraska
Dept of Banking and Finance Review, June 19, 2003 |
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"Yes, Equity-linked certificates of deposit are products
Nebraska financial institutions may (and do) sell." |
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Oregon Dept.
of Consumer & Business Svcs. Review, May 21, 2003 |
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"The Oregon Bank Act does not prohibit or specifically
address the issuance of indexed certificates of deposit. ORS 708A.400
provides that 'Oregon commercial banks may, consistent with applicable
law and safe and sound banking practices, offer deposit accounts upon
such terms and conditions as they consider appropriate." |
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Utah Dept
of Financial Institutions Review, December 2002 |
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The Law is silent on the subject. |
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Wyoming Dept
of Audit-Division of Banking Review, June 20, 2003 |
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"The Wyoming banking statutes do not directly address
equity indexed certificates of deposit. However, W.S. 13-2-101 does
permit a state chartered bank to engage in any activity that is usual
or incidental to the business of banking, and engage in any activity
that is permissible for a national bank with the prior approval of
the state banking commissioner. After review of the information submitted,
our office would likely approve this activity if a request from a
state chartered bank were received." |
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Virginia
Bureau of Financial Institutions Review, June 11, 2003 |
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"The Bureau of Financial Institutions is not aware
of any provision in the Virginia code, or any promulgated regulation
thereunder, that would preclude a Virginia's state-chartered bank
or savings and loan from issuing this type of certificate of deposit.
In addition, this Bureau presently has issued no policy or guidance
concerning this type of product." |
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FDIC Insurability,
November 18, 2002 |
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Opinion of insurability of "Dow Jones Indexed Certificates
of Deposit" and specific regulatory requirements. |
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Sound Liquidity
Risk Management Practices in Community Banks |
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The advent of non-bank competition and rise of third
party funding means that community banks now requires use of more
sophisticated liquidity risk management practices. |
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Letter from
Iowa Division of Banking, December 20, 2001 |
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Views of the Division of Banking with respect to time
certificate of deposit |
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Iowa Banking,
December 2001 |
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A new source of funding for community banks |
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