5 Key Points From Fed's Bank Control Proposal
Jacob Lutz, Gregory Parisi, James Stevens, Seth Winter and Zayne Tweed were published in Law360 for an article titled, “5 Key Points From Fed's Bank Control Proposal.” The article discusses proposed revisions by the Federal Reserve System’s board of governors to the rules for determining whether a company has control over another company for purposes of the Bank Holding Company Act and the Home Owners’ Loan Act. These revisions are intended to clarify and formalize the board’s current control framework promulgated under Regulation Y and Regulation LL. Regarding this they wrote, “The proposal promises to not only simplify the board’s decades-long, ad hoc approach to control evaluations at certain ownership levels, but also to create a comprehensive and transparent set of rules for holding companies and investors. Importantly, the board has introduced a series of tiered presumptions of control based on a company’s ownership of voting securities.”