Huntington National Bank 2012 Annual Report Download - page 22

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As a financial holding company, we are subject to additional laws and regulations.
In order to maintain its status as a financial holding company, a bank holding company's depository subsidiaries must all be both
well-capitalized and well-managed, and must meet their Community Reinvestment Act obligations.
Financial holding company powers relate to financial activities that are specified in the Bank Holding Company Act or
determined by the Federal Reserve, in coordination with the Secretary of the Treasury, to be financial in nature, incidental to an
activity that is financial in nature, or complementary to a financial activity, provided that the complementary activity does not pose a
safety and soundness risk. The Gramm-Leach-Bliley Act amends the Bank Holding Company Act and designates certain activities as
financial in nature, including:
xlending, exchanging, transferring, investing for others, or safeguarding money or securities,
xunderwriting insurance or annuities,
xproviding financial or investment advice,
xunderwriting, dealing in, or making markets in securities,
xmerchant banking, subject to significant limitations,
xinsurance company portfolio investing, subject to significant limitations, and
xany activities previously found by the Federal Reserve to be closely related to banking.
The Gramm-Leach-Bliley Act amendments also authorize the Federal Reserve, in coordination with the Secretary of the
Treasury, to determine if additional activities are financial in nature or incidental to activities that are financial in nature.
In addition, we are required by the Bank Holding Company Act to obtain Federal Reserve approval prior to acquiring, directly or
indirectly, ownership or control of voting shares of any bank, if, after such acquisition, we would own or control more than 5% of its
voting stock. Furthermore, the Dodd-Frank Act added a new provision to the Bank Holding Company Act, which requires bank
holding companies with total consolidated assets equal to or greater than $50 billion to obtain prior approval from the Federal Reserve
to acquire a nondepository company having total consolidated assets of $10 billion or more.
We also must comply with anti-money laundering and customer privacy regulations, as well as corporate governance, accounting,
and reporting requirements.
The USA Patriot Act of 2001 and its related regulations require insured depository institutions, broker-dealers, and certain other
financial institutions to have policies, procedures, and controls to detect, prevent, and report money laundering and terrorist financing.
The statute and its regulations also provide for information sharing, subject to conditions, between federal law enforcement agencies
and financial institutions, as well as among financial institutions, for counter-terrorism purposes. Federal banking regulators are
required, when reviewing bank holding company acquisition and bank merger applications, to take into account the effectiveness of
the anti-money laundering activities of the applicants.
Pursuant to Title V of the Gramm-Leach-Bliley Act, we, like all other financial institutions, are required to:
xprovide notice to our customers regarding privacy policies and practices,
xinform our customers regarding the conditions under which their nonpublic personal information may be disclosed to
nonaffiliated third parties, and
xgive our customers an option to prevent certain disclosure of such information to nonaffiliated third parties.
The Sarbanes-Oxley Act of 2002 imposed new or revised corporate governance, accounting, and reporting requirements on us. In
addition to a requirement that chief executive officers and chief financial officers certify financial statements in writing, the statute
imposed requirements affecting, among other matters, the composition and activities of audit committees, disclosures relating to
corporate insiders and insider transactions, code of ethics, and the effectiveness of internal controls over financial reporting.