BOAR D OF GOVERNOR S 

OF THE 

FEDERA L RESERV E SYSTEM 

WASHINGTON, D.C. 20551 

ADDRESS OFFICIAL CORRESPONDENCE 

TO THE BOARD 

March 30, 2012 

Mr. David Nason 

Chief Regulatory Officer 

and Compliance Leader 

General Electric Capital Corporation 

901 Main Avenue 

Norwalk, Connecticut 06851 

Dear Mr. Nason: 

This is in response to your letter dated February 9, 2012, requesting 

that General Electric Company ("GE"), Fairfield, Connecticut, be granted 

exemptions from the Board's regulatory reporting requirements for savings and 

loan holding companies ("SLHCs"). Specifically, you requested that (1) GE, the 

top-tier parent, be granted a temporary exemption from complying with the 

Board's reporting requirements until the Board finalizes the intermediate holding 

company regulations for grandfathered SLHCs, and (2) GE's intermediate SLHCs, 

General Electric Capital Corporation ("GE Capital") and GE Consumer Finance 

Inc., be granted until March 31, 2013, to comply with the Board's regulatory 

reporting requirements. 

Based on all the facts of record, the Director of the Division of 

Banking Supervision and Regulation, acting pursuant to authority delegated by the 

Board, and after consulting with the General Counsel, has determined that it is 

appropriate to grant GE a partial exemption from the Board's regulatory reporting 

requirements. In order to minimize the collection of information that is not 

meaningful in assessing the financial condition of a financial institution, 

GE Capital will be considered the top-tier SLHC for regulatory reporting purposes 

until further notice. GE Capital comprises approximately $545 billion of GE's 

$717 billion in total consolidated assets. GE's financial activities are principally 

conducted through GE Capital. Unlike the assets at the top-tier parent, which are 

commercial in nature, the assets and activities of GE Capital and its subsidiaries fit 

within the framework established in the Board's regulatory reports. 
However, the Board reserves the right at its discretion to require 

regulatory reporting from GE as the top-tier SLHC. In addition, the Board would 

continue to have the authority to request information during the supervisory 

process that is needed to effectively assess the impact of GE's commercial 

operations on, and its ability to serve as a source of strength to, GE Capital and its 

subsidiaries. 

Additionally, GE Capital and its subsidiary SLHCs will be exempted 

from filing the FR Y-9C/LP until the September 30, 2012, reporting period. 

GE Capital and its subsidiary SLHCs may submit the FR Y-9C/LP for the 

September 30, 2012, reporting period on a best-efforts basis, and this report will be 

granted confidential treatment. GE Capital and its subsidiary SLHCs are expected 

to be in full compliance with the Y-9C/LP filing requirements for the reporting 

period ending on December 31, 2012. The reporting deadlines for other reports, 

including the HB-11 and the FR Y-6, will not change. 

[footnote] 1

 As outlined in the Board's final notice on SLHC regulatory reports, ("December 

Notice"), GE Capital and its subsidiary SLHCs should submit their first FR Y-6 for 

year-end 2012. 76 Federal Register 81933 (December 29, 2011). Pursuant to the 

December Notice, GE Capital and its subsidiary SLHCs should submit other 

reports, such as the FR Y-l land FR Y-12 (nonbank subsidiaries and investments), 

FR Y-8 (affiliate transactions), and FR 2314 (foreign subsidiaries), beginning in 

2013. The December Notice did not extend the FR Y-10 (organizational structure 

and activities) to SLHCs but indicated that the Board would issue a separate notice 

on that form shortly. [end of footnote 1.] 

GE should continue to 

submit the FR 2320 report during the temporary exemption period (i.e., for the 

March 31 and June 30, 2012, reporting periods). 

Board and Reserve Bank staff believe that a two-quarter delay is an 

appropriate amount of time to allow GE Capital to rationalize data sources, design 

regulatory reporting tools, and establish a regulatory governance framework that 

will yield a more reliable and stable regulatory reporting infrastructure with better 

quality data. GE Capital and its subsidiary SLHCs also have been granted 

additional flexibility to provide best estimates for their first reporting period to 

assist with their transition. These terms are consistent with the regulatory reporting 

relief that the Board has granted to investment banks and other companies 

transitioning to bank holding company status. 

[footnote] 2

 In 2009, the Board granted 

recently converted to bank holding company status exemptions from and permitted 
modifications to the Board's reporting requirements. See, e.g., Board letter to 

Colm Kelleher, dated February 5, 2009, (Morgan Stanley), and Board letter to 

Sarah Smith, dated February 5, 2009, (The Goldman Sachs Group, Inc.). [end of footnote 2.] 

If you have any questions, please contact Sarah Dahlgren, Executive 

Vice President at 212-720-7537, or Caroline Frawley, Senior Vice President at 

212-720-1215 at the Federal Reserve Bank of New York. 

Very truly yours, 

[signed] Robert deV. Frierson 

Deputy Secretary of the Board 

cc: Sarah Dahlgren, Executive Vice President 

Federal Reserve Bank of New York 

Caroline Frawley, Senior Vice President 

Federal Reserve Bank of New York