In order for a bank to set up an ESOP for its employees, does it have to maintain the ESOP through its bank holding company or is it otherwise subject to any bank holding company rules? If so, what the relevant citations?

The Journal of Employee Ownership Law & Finance, published by the National Center for Employee Ownership (www.nceo.org), has included a number of excellence articles in recent years on the special rules relating to bank and bank holding company ESOPs. I recommend that you seek out these articles.