Regulatory Alerts2026-03-09 | Interpretive Letter 1191Added
Exemption from Section 23A Limits for Morgan Stanley Bank, N.A.
The Office of the Comptroller of the Currency grants Morgan Stanley Bank, N.A. an exemption from the quantitative limits of Section 23A of the Federal Reserve Act and Regulation W. This exemption permits the bank to acquire the equity of Morgan Stanley Europe SE and its subsidiary Morgan Stanley Bank AG from its parent, Morgan Stanley, despite the transaction exceeding the single affiliate limit of 10 percent and the aggregate affiliate limit of 20 percent of the bank's capital stock and surplus. The decision is based on joint findings by the OCC and the Federal Reserve Board that the exemption is in the public interest and consistent with Section 23A purposes, and the FDIC's determination that it does not present an unacceptable risk to the Deposit Insurance Fund.