The Federal Reserve Board Bank Holding Company Act Control Proposal: Observations and Reflections

June 2019

The Federal Reserve Board’s proposed Bank Holding Company Act and Home Owners’ Loan Act control regulations, published in late April, are the culmination of a long-promised initiative by Board officials to bring clarity to a notoriously opaque body of law and administrative principles concerning when a company controls a second company under the BHC Act. As is commonly known in the financial services industry, the BHC Act “control” determination is central to the applicability of the BHC Act to companies that have, or propose to have, investment or other business relationships with banking organizations regulated under the BHC Act, or BHC Act–regulated bank holding companies that establish such relationships with a second company.

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