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America’s Community Bankers commends the Office of Thrift Supervision for issuing a comprehensive strategy for governing mutual institutions, mutual holding companies and the mutual-to-stock conversion process. It is clear that the concerns of ACB’s mutual members were heard by OTS as part of the jointly sponsored "listening tour."

ACB is particularly pleased with OTS’s recognition that mutuals are different from stock institutions and should be examined and supervised differently. The new OTS approach will give mutuals that want to remain mutual new tools to do so and to better serve their communities. We encourage the FDIC and state regulators to adopt this approach for non-OTS regulated mutuals.

ACB also commends OTS for making the mutual holding company option more attractive to mutuals. The immediate effective date of the new powers and authorities for MHCs, as provided for in the Gramm-Leach-Bliley Act, will put MHCs on the same level playing field with commercial banks’ financial holding companies. OTS’s streamlining of the application process also enhances the desirability of creating a MHC rather than a full conversion to stock ownership.

ACB believes that the new streamlined mutual-to-stock conversion process, which provides more direction on business plans for using the conversion proceeds, should save institutions time and money. Also, standardizing the stock buyback rules so that institutions regulated by the OTS and the FDIC will be playing by the same rules will give newly converted institutions a greater opportunity to make their stock more attractive in the financial markets.