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WASHINGTON — NAFCU and the Association of Corporate Credit Unions have written in favor of expanding the bankers’ bank exemption from reserve requirements under the Federal Reserve’s Regulation D.

Institutions that (1) are organized solely to do business with other financial institutions; (2) are owned primarily by the financial institutions with which it does business; and (3) do not do business with the general public, are currently exempt from the so-called “sterile reserves.” Under a proposal by the Fed, the interpretation would be amended to add “and such others as the Board may determine on a case by case basis consistent with the purpose of the Act and the bankers’ bank exception,” to that list.

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