2018-03-15 | ISDRL-2018-001-DOBThe Washington State Department of Financial Institutions issued an interpretive statement defining key phrases within the Commercial Bank Act's change of control provisions. The Department determined that acting in concert includes knowing participation in joint activities or parallel actions toward acquiring control, as well as pooling voting interests pursuant to any arrangement. Additionally, the interpretation clarifies that holding proxies constitutes holding the power to vote, thereby triggering regulatory approval requirements for changes in bank control.