12 CFR § 9.100 - Acting as indenture trustee and creditor.

---
identifier: "/us/cfr/t12/s9.100"
source: "ecfr"
legal_status: "authoritative_unofficial"
title: "12 CFR § 9.100 - Acting as indenture trustee and creditor."
title_number: 12
title_name: "Banks and Banking"
section_number: "9.100"
section_name: "Acting as indenture trustee and creditor."
chapter_name: "COMPTROLLER OF THE CURRENCY, DEPARTMENT OF THE TREASURY"
part_number: "9"
part_name: "FIDUCIARY ACTIVITIES OF NATIONAL BANKS"
positive_law: false
currency: "2026-04-05"
last_updated: "2026-04-05"
format_version: "1.1.0"
generator: "[email protected]"
authority: "12 U.S.C. 24 (Seventh), 92a, and 93a; 15 U.S.C. 78q, 78q-1, and 78w."
regulatory_source: "61 FR 68554, Dec. 30, 1996, unless otherwise noted."
cfr_part: "9"
---


# 9.100 Acting as indenture trustee and creditor.

With respect to a debt securities issuance, a national bank may act both as indenture trustee and as creditor until 90 days after default, if the bank maintains adequate controls to manage the potential conflicts of interest.