American Insurance Association v. Robert L. Clarke, Comptroller of the Currency

ON PETITIONS FOR REHEARING

Opinion PER CURIAM.

On August 23, 1988, this panel issued its decision (see page 278) (“Initial Decision”). On October 24, 1988, the panel granted the petitions for rehearing filed by appellees (the Comptroller of the Currency, the United States, and Citibank) on two questions:

1. Was it appropriate for this court to address the Comptroller of the Currency’s interpretation of the Bank Holding Company Act?

2. Did Citibank’s acquisition of the American Municipal Bond Assurance Corporation require the prior approval of the Federal Reserve Board under section 4(c)(8) of the…