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Federal Reserve Finalizes Revised Control Framework: Initial Reactions
31 January 2020
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Yesterday, the Federal Reserve Board (“FRB”) adopted a new, comprehensive framework for determining “control” under the Bank Holding Company Act (“BHC Act”) and Home Owners’ Loan Act (“HOLA”).
The final rule 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 final rule largely retains the proposal’s tiered framework of control presumptions, but makes certain targeted changes. This analysis provides our high-level takeaways on the final rule. We plan to publish a comprehensive summary of the final rule in the future.
Satish M. Kini
Gregory J. Lyons
David L. Portilla
Will C. Giles
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