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affiliates agreement alleged application authority Bank Brokerage bank holding company bank regulators bank's Bankers Trust Board of Governors broker broker-dealer brokerage activities brokerage services call reports Cease and Desist Citicorp Civil Action commentors commercial paper Commission Complaint Comptroller Comptroller's conduct Court customers dealer debt Defendants NOLAN depositors directors disclose disclosure District due bill employees enforcement actions engage Exchange Act section exempt FDIC Federal Deposit Insurance Federal Reserve Board Federal Reserve System federal securities laws FHLBB filed financial institution funds Glass-Steagall Act intangible assets IntraWest investment investors issuance issued issuer loan associations material McFadden Act minimum capital ratios mortgage national banks offering Office placement preferred stock primary capital prohibits proposed purchase pursuant referral registered Rule S&Ls savings and loan secondary capital Section 10(b Section 16 Securities Act shareholders SHINEMAN statement statute subsidiary thereunder tion total assets transactions underwriting violations