Opinion for the Court filed by Circuit Judge STEPHEN F. WILLIAMS.
STEPHEN F. WILLIAMS, Circuit Judge:
Travelers Group, Inc. applied to the Board of Governors of the Federal Reserve System to become a bank holding company. Under § 3(a)(1) of the Bank Holding Company ("BHC") Act, 12 U.S.C. § 1842(a)(1) (1994), Travelers needed Board approval before it could proceed with its plan to acquire all of the voting stock of an existing bank holding company...
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