*428Opinion for the court filed by Circuit Judge KAREN LeCRAFT HENDERSON.
Dissenting opinion filed by Circuit Judge SILBERMAN.
KAREN LeCRAFT HENDERSON, Circuit Judge:SouthTrust Corporation (SouthTrust), a multi-state bank holding company based in Alabama, relocated the main office of a subsidiary bank from Alabama to Georgia. Before doing so, SouthTrust obtained approval from both the Office of the Comptroller of the Currency (OCC) and the Federal Reserve Board (Board). Synovus Financial Corporation (Synovus), a Georgia bank holding company, appeals the Board’s approval and claims that the Board misinterpreted Georgia’s banking laws. South-Trust has intervened, nominally in support of the Board, to challenge the Board’s authority over interstate relocations. We agree with SouthTrust that the Board is without such authority; therefore, we vacate its decision without reaching the issues Synovus raises.
I.
This case began when SouthTrust attempted to move the main office of one of its subsidiary banks across a river, to a location less than ten miles away. That bank, SouthTrust National Bank (STNB), was located in Phenix City, Alabama, and sought to move to Columbus, Georgia. The two cities, separated only by the Chattahoochee River, form a single metropolitan area as well as a single banking community. See Federal Reserve Board Order Approving Acquisition of a Bank and Establishment of a De Novo Bank (May 22, 1989), Joint Appendix (JA) 1, 3 n. 13; Decision of the Comptroller of the Currency on the Application of SouthTrust National Bank, Phenix City, Alabama, to Relocate its Main Office to Columbus, Georgia (Feb. 21, 1989), JA 125. In conjunction with the relocation, STNB planned to retain its Alabama branch offices and to establish a new branch office in Phenix City, whence its main office was moving.
SouthTrust’s first step was to file an application with the OCC. JA 6. The application initially met with protest from the Department of Banking and Finance of the State of Georgia (Georgia), which maintained that the relocation contravened Georgia law. In response to this protest, SouthTrust withdrew its proposals to retain STNB’s Alabama branches as STNB branches and to establish a new branch in Phenix City. In turn, Georgia withdrew its protest. See OCC Decision, JA 125. The OCC then granted SouthTrust’s application to relocate STNB in Georgia as a separate bank while SouthTrust continued to operate STNB’s former Alabama branches. In reaching its decision, the OCC explained that section 30(b) of the McFadden Act, 12 U.S.C. § 30(b), expressly governs main office relocations and that, by amendment, section 30 allows relocations within a thirty-mile radius whether or not the relocation crosses state lines.1 JA 127-30.
At the same time SouthTrust sought the OCC’s approval, the Board demanded that SouthTrust seek its approval as well. The Board asserted that the Douglas Amendment to section 3 of the Bank Holding Company Act (BHC Act), 12 U.S.C. § 1842(d) — which requires the Board to dis*429approve the “acquisition” by a bank holding company or its subsidiary of an out-of-state bank when state law does not allow it — also requires, by implication, the Board to prohibit the “relocation” of a bank across state lines if state law does not allow it.2 See 12 C.F.R. § 223.144. South-Trust initially resisted the Board, claiming that the Douglas Amendment does not apply to relocations. JA 42 (letter dated Aug. 18, 1987). But when the Board informed SouthTrust that it considered SouthTrust’s failure to file an application a violation of the Bank Holding Company Act, JA 45 (letter dated Sept. 20, 1988), SouthTrust filed an application under protest, JA 46 (protest letter and application, dated Nov. 3 and 4, 1988, respectively). Several months later, SouthTrust submitted a second application to the Board, this time requesting permission to acquire the SouthTrust Bank of Russell County, a de novo bank located in Phenix City. JA 153 (application dated Mar. 3, 1989). This national bank was intended to replace STNB in Phenix City and was to be kept entirely separate from STNB in Georgia. See Board Order, JA 3 n. 11.
After the Board asserted that STNB’s “relocation” was an “acquisition” within the meaning of the Douglas Amendment, Georgia followed suit and requested South-Trust to file an application with Georgia under its banking law regulating “acquisitions.” JA 44 (letter dated Aug. 26, 1987); Addendum D to SouthTrust Brief, A-26 (letter dated Sept. 20, 1988). When the Board formally requested Georgia to explain the meaning of section 7-l-621(d)(2) of the Georgia Code which controls the “acquisition” of a Georgia bank by an out-of-state bank holding company, JA 58 (letter dated Nov. 16, 1988), however, Georgia conceded that “Georgia law is silent on the issue of the interstate relocation of a banking subsidiary of a bank holding company,” JA 70 (letter dated Dec. 6, 1988). Further, Georgia explained that section 7-1-621(d)(2) permits an out-of-state bank to “acquire” a Georgia bank only if (i) “the out-of-state bank holding company is located in another state within the ‘Southern Region’ ”; (ii) the out-of-state bank’s home state “provides reciprocal privileges to bank holding companies located in Georgia”; and (iii) “the Georgia bank has been in existence and continuously operated as a bank for a period of five (5) years or more.” JA 70 (citing Ga.Code Ann. § 7-1-621).3 Georgia then concluded: “[T]he fact *430that Georgia law does not expressly authorize the proposed interstate relocation raises serious questions about whether the transaction violates Georgia policy and federal law.” JA 71.
Contrary to Georgia’s position, the Board, in its final order, concluded that “the Georgia statute permitting regional bank holding companies to ‘acquire ... a Georgia bank’ would encompass the relocation of [STNB], as proposed here.” JA 2. The Board then determined that the “acquisition” complied with Georgia law which in relevant part provides:
(d) ... no Georgia bank holding company or Southern Region bank holding company may:
******
(2) Directly or indirectly acquire a Georgia bank unless such bank has been in existence for five years or more prior to the date of application to the commissioner for approval of such acquisition.
Ga.Code Ann. § 7-1-621. According to the Board:
[STNB] does not currently qualify as “a Georgia bank” under Georgia law because [STNB] operates in Alabama. Under Georgia law, a Georgia bank is defined as a bank having offices only in Georgia. The proposed relocation, however, is an action that would cause [STNB] to maintain offices only in Georgia. As a result of that action, South-Trust would acquire a Georgia bank within the meaning of the Georgia regional banking statute. Accordingly, the Board believes that Georgia law specifically authorizes this method of acquiring a Georgia bank for purposes of the Douglas Amendment.
JA 2 (footnotes omitted). Thus, in sum, the Board concluded that Georgia law expressly authorizes relocations to Georgia and that Georgia law would permit the relocation in this case. The Board also summarily rejected SouthTrust’s contention that the Douglas Amendment does not grant the Board authority over relocations. JA 1-2.
In concluding that Georgia law permits STNB’s relocation, the Board specifically conditioned its approval on STNB’s receipt of “any necessary approvals from the Georgia Commissioner of Banking and Finance under the Georgia interstate banking statute.” JA 3. Georgia then alerted SouthTrust to the conditional nature of the Board’s order and informed it that Georgia had not yet issued any approval. JA 212 (letter dated Jun. 2,1989). Georgia further advised that “[s]uch action would now appear necessary ... in light of the [Board’s] characterization of the proposal as an ‘acquisition.’ ” Id. SouthTrust, however, failed to submit an application to Georgia and began preparations for the relocation of STNB to Georgia.
Georgia continued to insist that the Board’s decision was erroneous. In August 1989, Georgia informed SouthTrust:
We continue to believe that the silence of Georgia law on the matter of interstate relocations effectively prohibits such re-locations by a bank holding company subsidiary as a matter of federal law.
Exhibit A to Synovus Brief at 2a (letter dated Aug. 3, 1989). Georgia concluded that the Board, in determining whether the requirements of the Douglas Amendment had been satisfied, wrongly interpreted Georgia law. Id. Georgia then addressed a letter to the Board, reaffirming this view. Exhibit B to Synovus Brief (letter dated Sept. 21, 1989). In particular, Georgia emphasized that SouthTrust did not “acquire” a Georgia bank as allowed by Georgia banking laws but instead effectively created a new bank in Georgia. Id. at 7a-8a. Again Georgia concluded:
It is the position of the Department, therefore, that the method by which SouthTrust Corporation, an Alabama bank holding company, proposes to enter Georgia — by the relocation of SouthTrust to Georgia — is not permitted by the Georgia Act. Accordingly, the proposed transaction not only violates Georgia law, but also violates the Douglas Amendment.
Id. at 9a.
In October 1989, when SouthTrust was finalizing its move into Georgia and after the instant petition had been filed, Georgia *431notified the Board that SouthTrust had not satisfied the condition set forth in the Board’s order and asked the Board to suspend SouthTrust’s authority to relocate. Exhibit A to Federal Reserve Board Brief (letter dated Oct. 25, 1989). The Board rejected Georgia’s request, reasoning:
The Board’s order was conditioned on SouthTrust obtaining “any necessary approvals” from the Department. The Board took no position on whether or not any approvals were required under State law. To the Board’s knowledge, your office has not to date advised SouthTrust that approval by the Department is required by Georgia law for this transaction. Accordingly, at this time there is no basis to conclude that the condition precedent in the Board’s approval has not been met.
Exhibit B to Federal Reserve Board Brief (letter dated November 6, 1989). Georgia responded to the Board’s denial by letter dated November 13, 1989. See Exhibit A to Synovus Reply Brief. In that letter, Georgia fully exposed the dilemma caused by the Board’s interpretation of Georgia law:
If the interpretation used by [Georgia] is correct, then there would be no basis for an application to the Georgia Department of Banking and Finance and the transaction would have been denied by the [Board]. If on the other hand, the Board’s interpretation of Georgia law is found to be correct, then an application to the Georgia Department of Banking and Finance would in fact be required. ******
Neither the Board nor the Department can respond to the question of whether or not the Department of Banking and Finance’s approval is required until the appellate court completes its review and selects the proper interpretive analysis.
Id. at 3a-4a. In short, Georgia recognized that it could not interpret Georgia law in a manner inconsistent with the Board’s interpretation: if it did so, it would be unable to stop the relocation it deemed to be unlawful. As Georgia reasoned, a unified view of Georgia law was necessary: either the Board was correct, that is, Georgia law covered the transaction and Georgia’s approval was necessary; or Georgia law did not allow the relocation and no basis for approval existed. Id. Nonetheless, despite Georgia’s protest, the Board did not suspend its approval and STNB relocated to Columbus, Georgia, where it has been operating ever since.
Synovus, the Georgia bank holding company, appealed the Board’s order to this court pursuant to 12 U.S.C. § 1848. Syno-vus argues that the Board misinterpreted Georgia law and that the Douglas Amendment requires the Board to reject STNB’s relocation. SouthTrust, on the other hand, appears in this appeal as an intervenor— nominally in support of the Board — and reasserts its claim that the Board is without authority over STNB’s relocation. Both the Board and Synovus challenge SouthTrust’s ability, as an intervenor, to raise a separate issue. Following oral argument, we requested the parties and the OCC to submit supplemental briefs on the issue pressed by SouthTrust. Neither the Board nor the OCC responded to our order but instead the Attorney General submitted a brief on behalf of the “United States,” taking the position that the Board is without authority over relocations. While the Board has filed no post-argument brief separate from that of the Attorney General, it has at the same time taken no action— either in these proceedings or administratively — to reverse its stance.4
II.
In the typical civil appeal, the prevailing party may support the judgment by any argument raised below even though the lower court rejected it and based its decision on another ground. United States v. American Ry. Express Co., 265 U.S. 425, 435-36, 44 S.Ct. 560, 564, 68 L.Ed.1087 (1924); see Granfinanciera, S.A. v. Nordberg, 492 U.S. 33, 38-39, 109 S.Ct. 2782, 2788, 106 L.Ed.2d 26 (1989); Morley *432Constr. Co. v. Maryland Casualty Co., 300 U.S. 185, 191, 57 S.Ct. 325, 328, 81 L.Ed. 593 (1937). Having all the issues considered in one appeal promotes judicial efficiency and avoids the spectacle of parties bouncing back and forth between the courts of appeals and district courts in a one-issue-per-appeal system of appellate review. SouthTrust, as the prevailing party before the Board, is in a position comparable to a party who, having won in the district court, is now seeking to defend the result below on a ground raised but decided against it. The distinction is that, unlike a party in a district court action, SouthTrust did not automatically become an appellate party upon Synovus’s filing in the court of appeals. See Whitney Nat’l Bank v. Bank of New Orleans & Trust Co., 379 U.S. 411, 430-31, 85 S.Ct. 551, 563, 13 L.Ed.2d 386 (1965) (Douglas, J., dissenting). Rather, SouthTrust either had to intervene or had to petition for review as an aggrieved party in order to continue its participation, despite the fact that SouthTrust is in the center of the controversy. At that time, SouthTrust simply had no interest in filing a petition because it won below.
Thus, the question is whether SouthTrust’s appearance before this court as an intervenor rather than a party prevents it from defending its position on the same grounds it raised before the Federal Reserve Board. It would be strange if there were some jurisdictional bar preventing SouthTrust from doing so and we perceive none.
First, we disagree with the Board’s contention that SouthTrust lacks standing merely because the decision below was in its favor. It now appears that South-Trust’s victory before the Board was illusory. The Board’s final order was expressly conditioned on SouthTrust obtaining “necessary approvals from the Georgia Commissioner of Banking and Finance under the Georgia interstate banking statute regarding [STNB].” JA 3; see also Exhibit A to Federal Reserve Board Brief (Georgia informs Board of SouthTrust’s non-compliance with condition placed in Board order); Exhibit B to Federal Reserve Board Brief (Board acknowledges that approval was conditional). Since the filing of the petition for review, Georgia has informed South-Trust that, if this court upholds the Board’s decision, Georgia will require an application from SouthTrust. Exhibit A to Reply Brief for Synovus (letter dated November 13, 1989). Georgia has also made it clear that the application will be denied. See, e.g., Exhibit A to Synovus Brief (letter from Georgia to SouthTrust dated August 3, 1989) 2a (“We continue to believe that the silence of Georgia law on the matter of interstate relocations effectively prohibits such relocations”); Exhibit B to Synovus Brief (Letter from Georgia to Board dated September 21, 1989) 9a (“It is the position of the Department, therefore, that the method by which SouthTrust Corporation ... proposes to enter Georgia ... is not permitted by the Georgia Act”); Exhibit A to Synovus’s Reply Brief (letter from Georgia to Board dated November 13, 1989) (“Irrespective of the outcome of appellate review, the transaction should not go forward at this time because, in the event of one outcome, Department approval must be sought and, in the event of the alternative outcome, the transaction would likely be denied.”). Given the likelihood that Georgia will exercise the veto power it holds under the Board’s order and withhold approval of the relocation, we conclude that SouthTrust is “aggrieved” so as to have standing to seek review under 12 U.S.C. § 1848.
Second, 12 U.S.C. § 1848, which confers jurisdiction on this court, does not, by its terms, limit us to considering only the issues raised by the petitioner and the respondent. Petitions under section 1848, filed by “[a]ny party aggrieved by an order of the Board,” vest this court with “jurisdiction to affirm, set aside, or modify the order of the Board.” Our jurisdiction, in other words, is over the Board’s order, much the same as our jurisdiction in a typical civil appeal is over the judgment or decree of the district court. 28 U.S.C. § 1291; Ex parte Tiffany, 252 U.S. 32, 36, 40 S.Ct. 239, 240, 64 L.Ed. 443 (1920).
*433On what grounds we decide “to affirm, set aside, or modify” a Board order over which we have jurisdiction is a different matter. Cf. Fusari v. Steinberg, 419 U.S. 379, 387-88 n. 13, 95 S.Ct. 533, 539 n. 13, 42 L.Ed.2d 521 (1975). The general rule is that we will consider only issues raised by the petitioner and the respondent — here Sy-novus and the Board — and that intervenors must restrict their arguments to those issues, although our local rule encourages intervenors to present arguments “not made” by the party they are supporting. D.C.Cir.R. 11(e)(2). But there is nothing in our local rule or in Rule 15(d) of the Federal Rules of Appellate Procedure (intervention) that forbids an intervenor from raising, or a reviewing court from considering, an issue not mentioned by the petitioner or respondent but fully litigated in the agency proceedings and potentially determinative of the outcome of judicial review. Rule 15(d) simply requires the intervenor to file a motion setting forth its interest and the grounds on which intervention is sought, requirements SouthTrust fulfilled in this case.
In addition to the absence of anything in the relevant statutory provisions or the Federal Rules of Appellate Procedure that would compel us to turn SouthTrust away, there is nothing in the general principles of administrative law that prevents our hearing SouthTrust’s claim about the Board’s lack of authority to issue the order under review. SouthTrust is not an intermeddler. It fully participated in the proceedings before the Board and it raised the issue it now seeks to bring before us. Cf. 28 U.S.C. § 2348; Foundation on Economic Trends v. Heckler, 756 F.2d 143, 156 (D.C.Cir.1985). While courts must not decide issues left open by the agency, see, e.g., FPC v. Louisiana Power & Light Co., 406 U.S. 621, 647, 92 S.Ct. 1827, 1841, 32 L.Ed.2d 369 (1972), or sustain an order based upon reasoning the agency declined to adopt, see SEC v. Chenery Corp., 318 U.S. 80, 63 S.Ct. 454, 87 L.Ed. 626 (1943), we do neither here. Instead we overturn a specific ruling made by the Board, that it has authority over SouthTrust’s relocation, and vacate its final order.
Moreover, permitting SouthTrust to raise the authority issue makes eminent sense and is consistent with this court’s traditionally flexible approach toward appellate procedure. See Spann v. Colonial Village, Inc., 899 F.2d 24, 32-33 (D.C.Cir.1990) (finding “the requisite exceptional circumstances” to justify permitting cross-appeal despite party’s failure to file such); California Pub. Broadcasting Forum v. FCC, 752 F.2d 670, 683 n. 10 (D.C.Cir.1985) (rejecting seventh circuit view that intervenor may not oppose agency in any respect and observing that “[t]his circuit has not required such procedural niceties and has allowed intervention where an appeal was also possible”); New South Media Corp. v. FCC, 644 F.2d 37 (D.C.Cir.1981) (per cu-riam) (permitting party seeking modification or reversal of agency decision to participate in appeal as intervenor, rather than requiring that party to file its own appeal). To do otherwise would lead to absurd results. SouthTrust prevailed before the Board and therefore had no particular incentive to file a petition for review. Syno-vus did not file its petition for review until the eleventh hour.5 If we categorically refuse to consider any issues other than those raised in the petition for review, SouthTrust and similarly situated parties would be forced to file “protective” petitions for review, a practice that unnecessarily would exalt form over substance. All that would do is clutter our docket, increase the time and expense of litigation and perhaps breathe life into a dispute that otherwise might have come to rest.
The parties have briefed the authority issue fully. If we were to agree that the Board’s view of Georgia law was wrong, we would needlessly prolong this extended controversy by sending the case back to the Board only to have it return to us on SouthTrust’s petition after the Board exercised its disputed authority to block the *434relocation. This would make no sense for the same reasons it would make no sense in a case on appeal from a district court.
Our statement in Illinois Bell Tel. Co. v. FCC, 911 F.2d 776 (D.C.Cir.1990), does not preclude us from deciding the question SouthTrust presents. Illinois Bell establishes the general rule that “[a]n intervening party may join issue only on a matter that has been brought before the court by another party,” 911 F.2d at 786, but this is a prudential restraint rather than a jurisdictional bar. Like other such doctrines — exhaustion of administrative remedies, for instance — the statement in Illinois Bell should not be applied categorically. Cf. Natural Resources Defense Council, Inc. v. EPA, 824 F.2d 1146 (D.C.Cir.1987) (en banc). Furthermore, Illinois Bell is readily — and materially — distinguishable from the situation here. Unlike SouthTrust, the intervenor in Illinois Bell was the losing party in the administrative proceeding. It therefore had every incentive to petition for review of the administrative decision and its failure to do so was without excuse. Perhaps more importantly, the intervenor’s challenge in Illinois Bell had absolutely no substantive connection with the issues raised by the petition for review. 911 F.2d at 786. In contrast, the issue SouthTrust raises is “an essential” predicate to the question whether the Board properly interpreted Georgia law. Cf. Vance v. Terrazas, 444 U.S. 252, 258-59 n. 5, 100 S.Ct. 540, 544 n. 5, 62 L.Ed.2d 461 (1980). Synovus’s challenge to the Board’s order presupposes that the Board had authority to interpret Georgia law in the first place.
For all of the preceding reasons, we find it proper under the circumstances to address and decide the authority issue raised by intervenor SouthTrust.
III.
To determine whether the Board has authority over interstate relocations, “we begin, of course, with the language of the statute.” Board of Governors of Fed. Reserve Sys. v. Dimension Fin. Corp., 474 U.S. 361, 368, 106 S.Ct. 681, 685, 88 L.Ed.2d 691 (1986). “If the statute is clear and unambiguous ‘that is the end of the matter, for the court, as well as the agency, must give effect to the unambiguously expressed intent of Congress.’ ” Id. (quoting Chevron USA, Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837, 842-43, 104 S.Ct. 2778, 2781, 81 L.Ed.2d 694 (1984)).
The Board contends that its authority to approve or disapprove STNB’s relocation emanates from the Douglas Amendment, 12 U.S.C. § 1842(d). As we have noted, the Douglas Amendment provides that a bank holding company cannot “acquire” an out-of-state bank “unless the acquisition ... is specifically authorized by the statute laws of the State in which such bank is located.” 12 U.S.C. § 1842(d). Section 3 of the BHC Act enumerates the transactions that constitute an “acquisition” for the purpose of the Douglas Amendment: (i) “any action ... that causes a bank to become a subsidiary of a bank holding company”; (ii) “for any bank holding company to acquire direct or indirect ownership or control of any voting shares of any bank if, after such acquisition, such company will directly or indirectly own or control more than 5 per centum of the voting shares of such bank”; or (iii) “for any bank holding company of subsidiary thereof, other than a bank, to acquire all or substantially all of the assets of a bank.” 12 U.S.C. § 1842(a). Each of the transactions described in section 3 involves a bank holding company obtaining control over a subsidiary bank. Nothing in the statute, however, indicates that an “acquisition” as used in the Douglas Amendment includes the “relocation” of a subsidiary bank. Because the language used by Congress is free from ambiguity, we must interpret the statute according to its plain language and conclude that the Douglas Amendment does not grant the Board authority over relocations. See Chevron, 467 U.S. at 842-43, 104 S.Ct. at 2781.
In contrast to the language of section 3 of the BHC Act, the McFadden Act expressly grants the OCC authority over the “relocation” of bank headquarters. 12 U.S.C. § 30(b), supra note 1. Given the *435use of the word “relocation” in section 30(b) and the use of the word “acquisition” in the Douglas Amendment, we are hesitant to interpret acquisition to mean relocation. Additionally, that Congress expressly delegated authority to the OCC over reloca-tions strongly suggests that the Board, having not received any express authorization, lacks the concurrent jurisdiction it purports to assert.6 The Board’s expansive interpretation of the Douglas Amendment — that it authorizes the Board to review relocations for compliance with state banking laws — directly contradicts section 30 of the McFadden Act. Section 30 explicitly places authority over relocations with the OCC and has been generally construed to preempt state banking laws. See Ramapo Bank v. Camp, 425 F.2d 333 (3d Cir.), cert. denied, 400 U.S. 828, 91 S.Ct. 57, 27 L.Ed.2d 58 (1970); Traverse City State Bank v. Empire Nat’l Bank, 228 F.Supp. 984 (W.D.Mich.1964); cf North Dakota v. Merchants Nat’l Bank & Trust Co., Fargo, N.D., 634 F.2d 368 (8th Cir.1980) (§ 30 provision that OCC approve bank name changes preempts state law); Marion Nat’l Bank of Marion v. Van Buren Bank, 418 F.2d 121, 123 (7th Cir.1969) (“Relocation of a national bank is permitted in certain circumstances, and with the approval of the comptroller, by 12 U.S.C. § 30. The propriety of the move is not made to depend on state law.”). The Board’s construction of the Douglas Amendment, however, allows the Board to override the OCC’s decisions and to resurrect state law.
Acknowledging the absence of an express grant of authority, the Board makes two arguments to support its position. First, the Board claims that every approval of an interstate acquisition is subject to the implied condition that the acquired bank remain located in the same state:
[A] bank holding company’s authority to control a bank, which derives from the Board’s approval under the BHC Act for the acquisition of the bank, must necessarily be limited by, and cannot be broader than, the Board’s authority to grant approval for the acquisition in the first place. In other words, a bank holding company’s authority to continue to control a bank acquired pursuant to the terms of the BHC Act is subject to the limitation of the BHC Act that the bank remain located in the state specified in its application to the Board to acquire the bank.
12 C.F.R. § 225.144(c). Second, the Board reasons that its authority over interstate relocations is “necessary in order to give effect to the Congressional intent underlying the Douglas Amendment to maintain state control over the acquisition of banks within their borders.” 12 C.F.R. § 225.-144(e). Otherwise, the Board contends, the purpose of the Douglas Amendment could be thwarted if a bank holding company were authorized to acquire a bank in one state and then allowed to move the bank to another state where the company would not have been able to acquire it in the first place. According to the Board:
The Douglas Amendment was adopted to prevent the creation or expansion of interstate banking networks through acquisition by a bank holding company of control of a bank located outside of the holding company’s home state, without the explicit approval of the state in which the bank is located.
* * * # * *
As the legislative history of the Douglas Amendment indicates, prior to the enactment of the BHC Act, the acquisition and control of banks by bank holding companies was not regulated, and thus bank holding companies could establish networks of subsidiary banks in numerous states, while their subsidiary banks were *436limited by the McFadden Act [12 U.S.C. § 36] and state law to branching in a single state.
12 C.F.R. §§ 225.144(c) and (e).
The Board’s arguments must fail for the simple reason that they presume what they set out to prove and what we have already rejected: that the Douglas Amendment grants the Board authority over bank relo-cations. As we have already concluded, the clear statutory language and scheme indicate otherwise — the Douglas Amendment language expressly confers on the Board authority over bank acquisitions, as carefully defined in the amendment, not over bank relocations, while section 30 of the McFadden Act expressly places approval of relocations within the province of the OCC.7
This is not the first time that the Board has attempted to derive authority from the “plain purpose” of the BHC Act. In several related contexts the Board has asserted authority that it deemed necessary to fulfill its statutory mission; each time the courts have rejected the Board’s claim. In Board of Governors of Fed. Reserve Sys. v. Dimension Fin. Corp., 474 U.S. 361, 368, 106 S.Ct. 681, 685, 88 L.Ed.2d 691 (1986), the Board asserted that its authority to regulate institutions that accept “demand deposits,” 12 U.S.C. § 1841(c), also gave it authority to regulate institutions that did not formally accept demand deposits but did so as “a matter of practice.” 474 U.S. at 367-68, 106 S.Ct. at 685. In support of its authority, the Board argued that the statute should be “read with a view to the ‘policy of the regulation as a whole’ ” and not “read to negate the plain purpose of the legislation.” Id. at 373, 106 S.Ct. at 688. The Court unequivocally rejected this approach:
The “plain purpose” of legislation ... is determined in the first instance with reference to the plain language of the statute itself. Richards v. United States, 369 U.S. 1, 9, [82 S.Ct. 585, 591, 7 L.Ed.2d 492] (1962). Application of “broad purposes” of legislation at the expense of specific provisions ignores the complexity of the problems Congress is called upon to address and the dynamics of legislative action.
******
The statute may be imperfect, but the Board has no power to correct flaws that it perceives in the statute it is empowered to administer. Its rulemaking power is limited to adopting regulations to carry into effect the will of Congress as expressed in the statute.
Id. 474 U.S. at 373-74, 106 S.Ct. at 688-89. See also Citicorp v. Board of Governors of Fed. Reserve Sys., 936 F.2d 66 (2d Cir.1991) (BHC Act does not grant Board authority to regulate either bank holding company’s subsidiary or subsidiary’s subsidiary); MCorp Fin., Inc. v. Board of Governors of Fed. Reserve Sys., 900 F.2d 852 (5th Cir.1990) (BHC Act does not grant Board authority to require bank holding company to transfer funds to subsidiaries), rev’d on other ground, — U.S.-, 112 S.Ct. 459, 116 L.Ed.2d 358 (1991).
The Board’s reasoning in this case differs little from that offered in Dimension: in both instances the Board determined that because the express authority included in the BHC Act was insufficient to promote its broad purposes, the Act by implication granted the additional authority needed. We will not, and indeed cannot, allow the Board to do here what the Supreme Court refused to allow it to do in Dimension. As the Supreme Court reasoned: “If the Bank Holding Company Act falls short of providing safeguards desirable or necessary to protect the public interest, that is a problem for Congress, and not the Board or the courts, to address.” Dimension, 474 U.S. at 374, 106 S.Ct. at 689. Thus, even were *437we to accept the Board’s contention that the purpose of the Douglas Amendment would be thwarted if interstate relocations were not subject to Board approval, the language of the amendment limits the Board’s authority and we cannot remove that congressionally imposed limitation.
Finally, in an attempt to rescue the Board, Synovus claims the Board derives authority over STNB’s relocation from its uncontested authority over SouthTrust’s acquisition of the new Alabama bank, SouthTrust Bank of Russell County. According to Synovus, the relocation of STNB and the establishment of the new bank comprised a single transaction each aspect of which was an “integral and necessary element” of the whole. As a consequence, Synovus asserts, the Board had authority over each aspect of the transaction. We disagree. The relocation of STNB and acquisition of SouthTrust Bank of Russell County were apparently related transactions and disapproval of the acquisition might well have dissuaded SouthTrust from proceeding with the relocation. Such a relationship, however, does not make the relocation an acquisition nor does it confer on the Board the approval authority over relocations that Congress failed to grant it. Additionally, Synovus argues that the Board has specific authority to prevent evasions of the Douglas Amendment, see 12 U.S.C. § 1844(b), and that the Board is entitled to act here pursuant to that authority. This argument, however, runs directly contrary to the Board’s factual findings which expressly rejected the contention that the relocation was “a subterfuge designed to avoid the restrictions of the Douglas Amendment.” JA 3 n. 11. Accordingly, we find no support for Synovus’s assertion that the Board’s authority is necessary to prevent an evasion of the Douglas Amendment.
IV.
In sum, we conclude that we have jurisdiction to address SouthTrust’s argument that the Board is without authority to regulate a bank holding company’s interstate relocation of a “subsidiary bank” and, further, that the Board lacks such authority.8 Accordingly, the Board’s order is
Vacated.
. Section 30(b) provides in relevant part:
Any national banking association ... may change the location of its main office to any authorized branch location within the limits of the city, town, or village in which it is situated, or, with a vote of shareholders owning two-thirds of the stock of such association for a relocation outside such limits and upon receipt of a certificate of approval from the Comptroller of the Currency, to any other location within or outside the limits of the city, town or village in which it is located, but not more than thirty miles beyond such limits. 12 U.S.C. § 30(b). Before 1959, section 30 authorized national banks to relocate "to any other place within the same state not more than 30 miles distant.” Act of May 1, 1886, Ch. 73, § 2, 24 Stat. 18 (emphasis added). The OCC has consistently interpreted Congress’s deletion of the words “within the same state" to manifest its authorization of interstate relocations. See, e.g., Decision of the Comptroller of the Currency on the Application of Mark Twain Bank (Feb. 21, 1985), reprinted in Fed.Banking L.Rep. [CCH] ¶ 86,-180; Decision of the Comptroller of the Currency on the Application of The Bank of New Jersey (May 13, 1986).
. The Douglas Amendment to section 3 of the BHC provides:
[N]o application ... shall be approved under this section which will permit any bank holding company or any subsidiary thereof to acquire, directly or indirectly, any voting shares of, interest in, or all or substantially all of the assets of any additional bank located outside of the State in which the operations of such bank holding company’s banking subsidiaries were principally conducted ... unless the acquisition of such shares or assets of a State bank by an out-of-State bank holding company is specifically authorized by the statute laws of the State in which such bank is located, by language to that effect and not merely by implication.
12 U.S.C. § 1842(d) (emphasis added). Section 3 of the BHC Act also provides:
It shall be unlawful, except with the prior approval of the Board, (1) for any action to be taken that causes a company to become a bank holding company; (2) for any action to be taken that causes a bank to become a subsidiary of a bank holding company; (3) for any bank holding company to acquire direct or indirect ownership or control of any voting shares of any bank if, after such acquisition, such company will directly or indirectly own or control more than 5 per centum of the voting shares of such bank; (4) for any bank holding company of subsidiary thereof, other than a bank, to acquire all or substantially all of the assets of a bank....
12 U.S.C. § 1842(a).
. Georgia law defines an “acquisition” as:
(A) The merger or consolidation with another bank holding company;
(B) The acquisition of the direct or indirect ownership or control of voting shares of another bank holding company or bank if, after such acquisition, such bank holding company will directly or indirectly own or control more than 5 percent of the class of voting shares of such bank holding company or bank;
(C) The direct or indirect acquisition of all or substantially all of the assets of another bank holding company or bank; or
(D) The taking of any other action that would result in the direct or indirect control of another bank holding company or bank.
Ga.Code Ann. § 7-1-620(1) (1988).
. The Board’s pre-argument reply brief expressly argues its authority over relocations. Its opening brief primarily addresses the meaning of Georgia law.
. The Board issued its final order on May 21, 1989. Synovus did not file its petition until June 21, 1989, the last day on which a timely petition could be filed. See 12 U.S.C. § 1848 (requiring that petition be filed “within thirty days after the entry of the Board’s order”).
. The Board admits that its authority over acquisitions by bank holding companies is intended to supplement the prohibitions set forth in the McFadden Act and to prevent evasion of that Act. See 12 C.F.R. § 225.144(e). The Board also acknowledges that the McFadden Act expressly covers the interstate relocation of a subsidiary bank's main office. See 12 C.F.R. § 225.144(i) and (j). Despite the applicability of the McFadden Act to interstate relocations, however, the Board nonetheless maintains that the Douglas Amendment is also intended to apply to relocations.
. We express no opinion on whether the Board could assert authority over relocation of a bank whose acquisition it had approved based on express relocation conditions incorporated in the acquisition approval. Cf. United States v. Chesapeake & Ohio Ry. Co., 426 U.S. 500, 96 S.Ct. 2318, 49 L.Ed.2d 14 (1976). We note, however, that no such conditions were attached to the 1975 approval of SouthTrust’s acquisition of STNB. Nor can the Board argue that the STNB acquisition was subject to the "conditions” set forth in 12 C.F.R. § 225.144 as that section was not adopted until 1985.
. With all respect to our colleague in dissent, to equate the legal issues in this case with a Civil War campaign manifests not only a misunderstanding of those issues but also a lack of appreciation for a wrenching event in our country's history.