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June 23, 2014

The Board of Governors of the Federal Reserve System, FDIC, and Office of the Comptroller of the Currency (the "Agencies") jointly issued an Addendum to the "Interagency Policy Statement on Income Tax Allocation in a Holding Company". The Addendum was issued to ensure that insured depository institutions ("IDIs") in a consolidated group maintain an appropriate relationship regarding the payment of taxes and treatment of tax refunds. The Addendum instructs IDIs and their holding companies to review and revise their tax allocation agreements and ensure that the agreements expressly acknowledge

December 19, 2013

The Federal Reserve, FDIC and OCC (collectively, the "federal banking regulators") have submitted for comment a proposed joint supplemental guidance on income tax allocation agreements involving holding companies and insured depository institutions ("IDIs"). The proposed guidance is intended to supplement an interagency policy statement on income tax allocation issued by the federal banking regulators in 1998, which provided that a holding company receiving a tax refund from a taxing authority obtain such funds as agent for its subsidiary IDIs and affiliates. The proposed guidance would