8 Comments

As a bit of background, I work in the industry and such a large portion of the loan book being noted as "not formally rated" strikes me as odd. I've seen some banks do a rating system on more commodity pools (think consumer) based on quantitative metrics such as days past due, but theirs seems to be across several pools. Maybe they're relying on the regulators to rate the loans for them? I would definitely need to get comfortable with that by talking with management before spending time on this one.

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I am new to thrifts, so a basic question here. Where do you get the prospectus for the offering? Also, is it possible to participate in the offering if I live outside MA? perhaps I should go to the branch and open a bank account?

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Hi Houman, the SEC's EDGAR database is your friend for finding all filings...https://www.sec.gov/edgar/searchedgar/companysearch.html.

According to the prospectus, the first priority will be to depositors as of 12/31/20 and then to depositors as of 3/10/22 so you're probably out of luck on this particular one. I believe it's a case by case basis whether or not a mutual will take out of state deposits.

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SEC Enforcement Actions

Here are some pending or past SEC enforcement actions brought against individuals in connection with mutual bank conversions (with links to litigation releases posted on the SEC’s website):

SEC v. Bert Fingerhut et al.:

http://www.sec.gov/litigation/litreleases/2007/lr20118.htm

SEC v. Jay Slesinger et al and SEC v. Jay Rice:

http://www.sec.gov/litigation/litreleases/2006/lr19714.htm

http://www.sec.gov/litigation/admin/2006/34-54535.pdf

SEC v Robert R. Ross, et al.:

http://www.sec.gov/litigation/litreleases/lr19288.htm

SEC v. Jakubowski: http://www.sec.gov/litigation/litreleases/lr15580.txt

SEC v. Parnes, et al.: http://www.sec.gov/litigation/litreleases/lr16877.htm ; http://www.sec.gov/litigation/litreleases/lr17865.htm

In the Matter of Henry Salzhauer, et al.: http://www.sec.gov/litigation/litreleases/lr17215.htm; http://www.sec.gov/litigation/admin/34-45005.htm

SEC v. James D. Sterling: http://www.sec.gov/litigation/litreleases/2010/lr21714.htm

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It is absolutely illegal for a depositor to "arrange a deal" with another person to share the potential profits of a mutual conversion. A depositor can borrow funds to buy conversion shares, but not allow his share rights to go to another ineligible individual. This can, and certainly has, led to prosecution with enormous fines and incarceration in the past.

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Thanks for commenting and good point, you’re absolutely right. I have removed the joke because I don’t think the facetious nature of the remark translates well to paper.

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That kind of "joke" is about as funny as "joking" about carrying a bomb as you get screened by TSA. Just ask any of the New Alliance "jokers".

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I will concede it may have been in poor taste and unprofessional but thought the winking smiling face made it clear it was in jest. My apologies.

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