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within the classification of a building and loan association and
that, second, substantially all of its business must be confined
to making loans to members. Id. at 710. Because the definition
of a building and loan association was not codified in State law,
the analysis focused on State law interpretation of the
characteristics of a building and loan association, consistent
with the second requirement in section 101(4), that substantially
all of an association’s business must be confined to making loans
to members. Id. at 710-711. The Court concluded:
if a corporation does not substantially meet the
generally recognized criteria of a bona fide building
and loan association, it is not such a tax exempt
association as is contemplated by the statute,
regardless of what name it may have or how it may be
designated or classified by the State statute under
which it was organized. [Id. at 715.]
Respondent asserts that, under the Cambridge analysis, when
the Federal statute does not provide a definition, we must rely
on the law of the chartering jurisdiction to determine the
appropriate definition. Respondent argues that the chartering
jurisdiction provides for the separate treatment of entities
classified as building and loan associations from that afforded
to other financial institutions. Both Southwest and Pinellas
were chartered as Florida banking corporations and were,
therefore, subject to and operated under the regulatory authority
of the Florida Department of Banking and Finance, as were all
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