Key takeaways: 

• On March 31, 2021, the Federal Reserve Board (the “FRB”) published a series of Frequently Asked Questions (“FAQs”) on each of its Regulations H, K, L, O, W and Y.
• The FAQs mostly consist of existing legal interpretations regarding these regulations.  However, the FAQs also include FRB interpretations “not previously available in written form.”  In particular, the Regulation W FAQs represent the most comprehensive articulation of FRB staff interpretations of the rule since the preamble to its adopting release in 2002.  
• In this Debevoise In Depth, we summarize key aspects of the new FAQs, focusing on guidance that either appears to modify precedent or was previously unpublished.