Opinion Letter

April 2, 1990

Dear M ________:

Thank you for giving us the opportunity to clarify our interpretation of Financial Code Section 1761. By letter dated March 23, 1990, you formally posed the following question: “. . . whether we can deposit the CDs issued by the Japanese Bank as asset pledge.” Confirming our Monday morning telephone discussion regarding this section of the Financial Code, it is our position that ________, may not count any certificates of deposit issued by any bank domiciled in Japan, as eligible assets for pledging purposes. In addition, ________ may not count any certificates of deposit issued by any bank that is controlled by a bank or other person domiciled in Japan.

If you have any other questions regarding this matter, please do not hesitate calling me.

Very truly yours,

JAMES E. GILLERAN
Superintendent of Banks

By

MASANORI YAMAGUCHI
Assistant Deputy
Superintendent of Banks