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Section 591(b) was enacted in response to changing regulations in
the banking industry that allowed mutual savings banks to convert
to stock savings banks. H. Conf. Rept. 97-215, at 284-285
(1981). In order to facilitate the conversions and not frustrate
regulatory policy, section 591(b) provided that, “for purposes of
this part, the term ‘mutual savings bank’ includes any bank * * *
which has capital stock represented by shares, and * * * which is
subject to, and operates under, Federal or State laws relating to
mutual savings bank”. Accordingly, mutual savings banks that
converted to stock savings banks continued to qualify as mutual
savings banks for purposes of the reserve method of accounting
for thrift institutions under section 593. The amendments were
intended to “apply to both mutual savings banks which convert
into stock associations and to newly formed stock associations so
long as the institution is operated as a savings institution and
is subject to the same Federal or State regulatory scheme as a
mutual savings bank chartered under Federal or State law”.
H. Conf. Rept. 97-215, at 284-285 (1981).
Petitioner argues that Pinellas and Southwest qualify as
mutual savings banks because they were chartered as banks with
capital stock represented by shares, as required by section
591(b), and were subject to and operated under the regulatory
authority of the Florida Department of Banking and Finance, as
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