Each depositor insured to at least $250,000 per insured bank

Sale of Bonds from Bank's Investment Portfolio pursuant to a collateralized Put Accounting Treatment

FDIC-85-20

August 14, 1985

Pamela E. F. LeCren, Attorney

In response to your August 2, 1985 letter with respect to the sale by *** Bank of bonds pursuant to a collateralized put, please be advised that the change in accounting treatment described in your letter does not affect my April 16, 1985 opinion that the transaction in question does not constitute an unlawful guarantee of the obligations of others as prohibited by section 332.1(d) of the FDIC's regulations.