US Federal Reserve Delays Effective Date for Final Rule on "Control" Determinations Under Certain Banking Laws
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March 31, 2020 TO: ICI MembersICI Global Members SUBJECTS: Compliance
International/Global
Investment Advisers RE: US Federal Reserve Delays Effective Date for Final Rule on "Control" Determinations Under Certain Banking Laws
As we previously informed you, the US Federal Reserve Board (FRB) adopted a final rule to revise its regulations related to determinations of whether a company has an ability to exercise a controlling influence over another company for purposes of the Bank Holding Company Act or the Home Owners’ Loan Act.[1] The final rule was to become effective on April 1.
In a press release issued today, the FRB announced that it will delay the effective date of the rule by six months, to September 30.[2] The release states that “[t]he delay will reduce operational burden and allow institutions to focus on current economic conditions.” It notes that “[n]o changes were made to the framework itself.”
Rachel H. Graham
Associate General Counsel
Frances M. Stadler
Associate General Counsel & Corporate Secretary
endnotes
[1] For a discussion of the final rule and its implications for regulated US and non-US funds, see Institute Memorandum 32201, dated Feb. 7, 2020.
[2] Federal Reserve Board announces it will delay by six months the effective date for its revised control framework, press release dated March 31, 2020, available at https://www.federalreserve.gov/newsevents/pressreleases/bcreg20200331a.htm.