Joyce Aston - Page 21

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               b.  Not a Savings and Loan                                             
               Through section 591, subsection 165(l)(3)(B) refers to "mutual         
          savings banks, cooperative banks, domestic building and loan                
          associations, and other savings institutions chartered and                  
          supervised as savings and loan or similar associations under                
          Federal or State law".  None of the three entities fit within these         
          categories.  Petitioner has failed to introduce any evidence that           
          either BCCI, S.A., its IOMB, or its Los Angeles agency office               
          qualifies under subsection 165(l)(3)(B).                                    
               c.  Not a Credit Union                                                 
               Subsection 165(l)(3)(C) refers to credit unions whose deposits         
          are insured under Federal or State law.  The evidence before us             
          clearly establishes that deposits at BCCI, S.A., its IOMB, and its          
          Los Angeles agency office were not insured under Federal or State           
          law.  Accordingly, the three institutions do not qualify as credit          
          unions under subsection 165(l)(3)(C).                                       
               d.  Not a Supervised and Chartered "Similar Institution"               
               Subsection 165(l)(3)(D) provides a final exception for "any            
          similar institution" that is chartered and supervised under Federal         
          or State law.  In order to be a "qualified financial institution"           
          under section 165(l)(3)(D), an entity must be (1) supervised under          










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