BOAR D O F GOVERNOR S 

OF TH E 

FEDERA L RESERV E SYSTEM 

WASHINGTON , D. C. 2055 1 

ADDRESS OFFICIAL CORRESPONDENCE 

TO THE BOARD 

October 31, 2012 

Mr. David L. Roberts 

President 

National Advisors Holdings, Inc. 

8717 West 110th Street 

Suite 700 

Overland Park, Kansas 66210 

Dear Mr. Roberts: 

This is in response to the application by National Advisors Holdings, Inc. 

("National Advisors"), Overland Park, Kansas, to deregister as a savings and loan holding 

company ("SLHC") pursuant to section 604(i) of the Dodd-Frank Act, 

12 U.S.C. § 1467a(a)( 1 )(D)(ii)(II), and the Board's Regulation LL, 12 CFR 238.4(d). National 

Advisors seeks to deregister based on the representation that its subsidiary federal savings 

association, National Advisors Trust Company, FSB ("Trust Company"), Overland Park, 

Kansas, qualifies as a trust-only company pursuant to section 2(c)(2)(D) of the Bank Holding 

Company Act, 12 U.S.C. § 1841(c)(2)(D). 

National Advisors is an SLHC because it owns Trust Company. Trust Company 

is a limited-purpose savings association that serves as a trustee and custodian for its customers. 

In connection with the application, National Advisors and Trust Company have 

committed as follows: 

1. Trust Company will not, without the prior approval of the Board or its staff, engage in 

activities beyond those that are permissible under section 5(n) of the Home Owners' 

Loan Act, 12 U.S.C. § 1464(n), and its implementing regulations. 

2. Trust Company will hold at least 99 percent of its deposits in a trust or fiduciary 

capacity (excluding from the calculation the amount required to maintain deposit 

insurance from the Federal Deposit Insurance Corporation ("FDIC")). 

3. Trust Company does not maintain and will not accept demand deposits or deposits that 

the depositor may withdraw by check or similar means for payment to third parties or 

others. 

4. Trust Company does not and will not make commercial loans. 

5. Trust Company will not obtain payment or payment related services from any Federal 
Reserve Bank and will not seek to exercise discount or borrowing privileges with the 

Federal Reserve. 

6. No affiliates of Trust Company will offer or market deposits of Trust Company that are 

insured the FDIC. 

Based on the foregoing and all the facts of record, including the most recent call 

report and report of examination of Trust Company and consultation with the Office of the 

Comptroller of the Currency, Trust Company's primary federal regulator, the General Counsel 

and the Director of the Division of Banking Supervision and Regulation, acting pursuant to 

authority delegated by the Board, have approved the application by National Advisors to 

deregister as an SLHC. This action is taken in reliance on all the facts of record, including all 

the representations and commitments made to the Board in connection with the application. 

Those representations and commitments constitute conditions imposed in writing in connection 

with the approval of National Advisors' application to deregister as an SLHC and, as such, may 

be enforced in proceedings under applicable law. Any change in the representations or 

commitments may result in a different conclusion and should be reported to Board staff 

promptly. 

Sincerely yours, 

[signed] Robert deV. Frier son 

Secretary of the Board 

cc: Kevin L. Moore, Senior Vice President 

Federal Reserve Bank of Kansas City 

Office of the Comptroller of the Currency