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Federal Reserve Proposes to Clarify and Revise Control Framework
24 April 2019
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Yesterday, the Federal Reserve Board (the “FRB”) proposed a new, comprehensive framework for determining “control” under the Bank Holding Company Act and Home Owners’ Loan Act.
The proposal is intended to simplify and clarify the FRB’s standards for determining whether a company exercises a controlling influence over the management or policies of another company and, therefore, “controls” the other company under the BHC Act or HOLA.
The proposal would codify certain aspects of the FRB’s controlling influence precedent and, at the same time, would make some significant changes, including with respect to de-control (
, the so-called “tear-down” rules).
Satish M. Kini
Gregory J. Lyons
Alison M. Hashmall
David G. Sewell
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