December 13, 2021 

Alcides I. Avila, Esq. 

Avila Rodriguez Hernandez Mena & Garro LLP 

2525 Ponce de Leon Blvd., Penthouse 12th Floor 

Coral Gables, Florida 33134 

Dear Mr. Avila: 

This letter responds to the request dated August 16, 2021, and amended on 

October 29, 2021, by Belkis Macedo de Graterol, Candida Isabel Macedo Rodrigues, 

Carmen Elena De Abreu, Ernesto Joaquin de Abreu Gonzalez, Javier Macedo Rodriguez, 

Jose Alberto de Abreu Gonzalez, Mercedes Coromoto de Abreu de Castanho, and Nelly 

Macedo Rodriguez (collectively, “Parties”) for limited relief from the foreign national 

commitments (the “Commitments”) that the Parties made to the Board of Governors of 

the Federal Reserve System (“Board”), in connection with an after-the-fact notification 

pursuant to the Change in Bank Control Act1

 to directly and indirectly retain outstanding 

voting shares of Ocean Bankshares, Inc., and its nonmember bank subsidiary Ocean 

Bank, both of Miami, Florida. 

The Parties have requested relief from section 5(b) of the Commitments 

(“Foreign Bank Reporting Commitment”), which requires the Parties to annually provide 

certain information related to Banco Plaza C.A., Caracas, Venezuela (“Banco Plaza”). At 

the time the Parties submitted the Commitments, the Parties, in the aggregate, owned 

over ten percent of Banco Plaza and Javier Macedo Rodriguez and Ernesto Joaquin de 

Abreu Gonzalez were members of the board of directors of Banco Plaza. Accordingly, 

the Commitments included the Foreign Bank Reporting Commitment to provide greater 

transparency into the financial condition of Banco Plaza. The Parties represent that they 

have now divested all of their shares in Banco Plaza, except 

 The Parties also represent that Javier 

Macedo Rodriguez and Ernesto Joaquin de Abreu Gonzalez are no longer members of the 

1

 12 U.S.C. § 1817(j). 
- 2 - 

board of directors of Banco Plaza, and that none of the Parties is a director, officer, or 

employee of Banco Plaza. 

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

and Regulation, acting pursuant to authority delegated by the Board under section 

265.7(a)(2) of the Board’s Rules Regarding Delegation of Authority,2

 and after 

consulting with the General Counsel, has approved the request for relief from the Foreign 

Bank Reporting Commitment. This action is based on all the facts of record and the 

representations made by the Parties to the Board in connection with the request. Any 

change in the facts presented could result in a different conclusion and should be reported 

immediately to Board staff. 

This action is also based on all commitments provided by the Parties in 

support of the request. These commitments are conditions imposed in writing in 

connection with the Board’s decision and, as such, may be enforced in proceedings under 

applicable law. This determination should not be construed as granting relief from any 

other conditions or commitments to which the Parties may be subject. 

Very truly yours, 

Margaret McCloskey Shanks (signed) 

Margaret McCloskey Shanks 

Deputy Secretary of the Board 

 

2

 12 CFR 265.7(a)(2).