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The final rule provides that a CSA be treated as a federal savings association for purposes of merger, consolidation, dissolution, conversion, conservatorship, and receivership, but a CSA is permitted to retain branches and agency offices that the federal savings association operated on the date of election.
An operating subsidiary is a corporation, LLC, or similar entity that engages in activities that are part of, or incidental to, the business of banking as determined by the OCC or other statutory authority.