Imperial Thrift and Loan Association, §5.L; §5.M, 5/2/1997

Imperial Thrift and Loan, a California-chartered industrial loan company that is subject to supervision and regulation by the Federal Deposit Insurance Corporation (“Imperial”), proposes to sell certificates of deposit and other depository instruments that are, in effect, debts of Imperial to depositors. The staff noted that §5.L is not available because Imperial is not a “bank” subject to regulation under federal or state law, but confirmed that §5.M is available so long as sales in Texas are restricted to persons that will not own depository instruments in excess of the FDIC insurance limit.