In Board of Governors v. Investment Company Institute, 450 U.S. 46, 101 S.Ct. 973, 67 L.Ed.2d 36 (1981) ("ICI "), the Supreme Court upheld the Board's determination that bank holding companies could act as investment advisers to closed-end investment companies under the Banking Act of and the Bank Holding Company Act ("BHCA"). In rejecting respondent's argument that sections 16 and 21 of the Act applied to bank holding companies as well as banks, the Court discussed the structure of the Act: "Sections 16 and 21 flatly prohibit banks from engaging in the underwriting business. Organizations affiliated with banks, however, are dealt with by other sections of the Act. Section 19(e), 48 Stat. 188, repealed in pertinent part, 80 Stat. 242, prohibited bank holding companies from voting the shares of a bank subsidiary unless the holding company divested itself of any interest in a subsidiary formed for the purpose of or "engaged principally" in the issuance or underwriting of securities. More importantly, Sec. 20 of the Act, 48 Stat. 188, prohibits national banks or state bank members of the Federal Reserve System from owning securities affiliates, defined in Sec. 2(b), 48 Stat. 162, that are "engaged principally" in the issuance or underwriting of securities. Thus the structure of the Act reveals a congressional intent to treat banks separately from their affiliates. The reading of the Act urged by respondent would render Sec. 20 meaningless." 450 U.S. at 59 n. 24, 101 S.Ct. at 983 n. 24. The Court re-emphasized the Act's different treatment of banks and bank affiliates later in the opinion. Citing Agnew, the Court wrote: "a less stringent standard should apply to determine whether a holding company or affiliate has violated Sec. 20 than is applied to a determination of whether a bank has violated Secs. 16 and 21." Id. at 61 n. 26, 101 S.Ct. at 984 n. 26. Similarly: the words "principally engaged," contained in both Secs. 19(e) and 20 of the Glass-Steagall Act, the sections applicable to bank affiliates, indicate a significantly less stringent test for determining the permissibility of securities-related activity than does the word "engaged," contained in Secs. 16 and 21, the sections applicable to banks. Id. at 71 n. 46, 101 S.Ct. at 989 n. 46.