Which view means the fresh views of your Work environment of your State Comptroller at that time it actually was rendered

The newest viewpoint ong other things, there have been then court circumstances or statutory amendments you to definitely incur to your facts talked about from the viewpoint.

Standard Civil Rules 10(3), 11(2): New provisions out of Standard safe loans online Civil Rules 10(1)(h) one maximum to help you 3 months the definition of from an enthusiastic eligible letter away from credit awarded because shelter getting local government dumps and you will assets dont apply to an irrevocable page out-of credit awarded from the a being qualified federal mortgage bank.

Especially, you ask perhaps the arrangements from General Municipal Rules 10(1)(h) you to essentially limit to help you 3 months the phrase out of an enthusiastic eligible page regarding borrowing from the bank approved since the cover for local government dumps and you may financial investments applies to an enthusiastic irrevocable page from borrowing granted by a keen FHLB.

Standard Civil Rules 10 and you will 11 regulate the latest deposit and you will temporary financing from monies from the local governments, and counties. Below General Municipal Law ten and you may 11, all places and financial investments over the quantity insured significantly less than specifications of your own Federal Deposit Insurance coverage Act 1 must be secure relative to Standard Municipal Rules 10(3) (General Civil Laws 10, 11).

This will be responding to the query about your usage of a page out-of borrowing from the bank issued of the a national mortgage financial (hereinafter FHLB) once the protection for state places

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Standard Municipal Rules 10(3) will bring numerous options for protecting like excessive number, such as the desired from an qualified page off borrowing, payable on the local government, because safety into the payment of 1 hundred or so 40 %, of the aggregate quantity of public places throughout the state, and you can agreed upon attention (Standard Civil Rules 10[c][i]). Qualified page away from borrowing from the bank is defined for this function typically Municipal Law 10(1)(h) to suggest:

[A]n irrevocable letter of credit issued in favor of the local government for an expression not to go beyond 90 days by the a lender (other than the bank with which the money is being deposited or invested) whose commercial paper and other unsecured short-term debt obligations (or, in the case of a bank which is the principal subsidiary of a holding company, whose holding company’s commercial paper and other unsecured short-term debt obligations) are rated in one of the three highest rating categories (based on the credit of such bank or holding company) by at least one nationally recognized statistical rating organization or by a bank (other than the bank with which the money is being deposited or invested) that is [in compliance] with applicable federal minimum risk-based capital requirements (emphasis added).

Municipal Loans — Deposits and you may Opportunities (title from an enthusiastic irrevocable page regarding borrowing from the bank issued once the defense by the a being qualified government financial lender)

For purposes of General Municipal Law 10, a bank is defined to mean a national banking association (see 12 USC 21 et seq.) or a corporation, other than a trust company, organized under or subject to the provisions of article 3 of the New York State Banking Law (General Municipal Law 10[d]; Banking Law 2). FHLBs, which are supervised by the Federal Housing Finance Board, are separate regional corporations, owned by those savings and loan associations, cooperative banks, homestead associations, insurance companies, savings bank, and other insured depository institutions within the region that are eligible and have become members of the FHLB (12 USC 1422a, 1424, 1426, 1432). 2 As such, they do not fall within the definition of bank for purposes of acceptance of an eligible letter of credit under section 10 of the General Municipal Law.

General Municipal Legislation 10(3)(c) was amended for the 2002, not, to particularly site the fresh acceptance because of the local governing bodies from an enthusiastic irrevocable page out of credit issued by the a keen FHLB in order to secure too-much deposits (L 2002, ch 615, active endment as well as renumbered present paragraph (c) of subdivision step three regarding point 10, as brand new subparagraph (c)(i).