Allstate Bank §5.L; §5.M; §12; Rule 109.17, No Action Recommended, 4/9/2002

Affiliates of federal savings bank proposed to offer and sell savings bank CD’s, including those in excess of FDIC insurance limits. Registration of certificates of deposit issued by federal savings bank not required when sold by issuer or its personnel under §5.L. Dealer registration required for agents of affiliated insurance company selling CDs. §5.M exemption not available where CDs could exceed amount of FDIC insurance. Staff expressly declined to adopt holding of Marine Bank v. Weaver that CDs are not securities, but offered to consider waiver of general securities examination in connection with registration of agents who were to conduct limited securities-related activities.