Regulatory Alerts1994-01-01
Memo 1994-14 Repurchase Agreements with Municipalities
Assistant Deputy Commissioner Kevin Glendening issued this memo to guide state-chartered banks on complying with an Attorney General opinion regarding repurchase agreements with municipalities. The guidance mandates a delivery versus payment structure where securities are transferred to a municipal custodian to ensure actual ownership transfer, while allowing banks to retain securities on their books for recordkeeping under specific accounting categories. Examiners will review these agreements for statutory compliance, requiring banks to clearly define terms and maintain accurate records of the securities involved.
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