ARTICLE
23 April 2020

Federal Reserve Board To Extend Effective Date For The Final Control Regulation

SS
Shearman & Sterling LLP
Contributor
Our success is built on our clients’ success. We have a long and distinguished history of supporting our clients wherever they do business, from major financial centers to emerging and growth markets. We represent many of the world’s leading corporations and major financial institutions, as well as emerging growth companies, governments and state-owned enterprises, often working on ground-breaking, precedent-setting matters. With a deep understanding of our clients' businesses and the industries they operate in, our work is driven by their need for outstanding legal and commercial advice.
On March 31, 2020, the Board of Governors of the Federal Reserve System (the "Board") announced that it has decided to delay the effective date of its final rules...
United States Corporate/Commercial Law
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On March 31, 2020, the Board of Governors of the Federal Reserve System (the "Board") announced that it has decided to delay the effective date of its final rules revising the Board's framework for determining whether a company controls another for purposes of the Bank Holding Company Act or the Home Owners' Loan Act (the "Final Control Regulation"). The Final Control Regulation was to become effective on April 1, 2020, but pursuant to the Board's new release, the effective date has been pushed back by two quarters to September 30, 2020. The Board did not make or discuss any substantive changes to, or interpretations of, the Final Control Regulation. For more on the content of the Final Control Regulation, please refer to our previous client note, Federal Reserve Board Adopts Final Control Rule.

The Board set forth two rationales for delaying the effective date: first, that the COVID-19 outbreak has significantly impacted banks and other financial institutions and resulted in market dislocation; and second, that many regulated institutions have expressed a desire to consult with Board staff on existing investments and relationships. The extension thus acknowledges that banks and other companies affected by the Final Control Regulation may need more time to analyze its impact and consult with the Board about prior investments and relationships. The delayed effective date also allows companies greater flexibility to focus on other obligations and concerns that have arisen in the wake of the COVID-19 pandemic.

Special thanks to Caitlin Hutchinson Maddox for her contribution to this publication.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

ARTICLE
23 April 2020

Federal Reserve Board To Extend Effective Date For The Final Control Regulation

United States Corporate/Commercial Law
Contributor
Our success is built on our clients’ success. We have a long and distinguished history of supporting our clients wherever they do business, from major financial centers to emerging and growth markets. We represent many of the world’s leading corporations and major financial institutions, as well as emerging growth companies, governments and state-owned enterprises, often working on ground-breaking, precedent-setting matters. With a deep understanding of our clients' businesses and the industries they operate in, our work is driven by their need for outstanding legal and commercial advice.
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