Federal Reserve Announces Delay in Effectiveness of New “Control” Framework

March 31, 2020

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Responding to the effects of COVID-19 on the U.S. economy and the desire of banks and investors to consult with Federal Reserve staff about the effects of the Federal Reserve’s new “control” rule on existing investments and relationships, the Federal Reserve announced that it was delaying the effective date of its new framework for analyzing “control” under the Bank Holding Company Act by two quarters, to September 30, 2020.  The Gibson Dunn Client Alert on the new framework may be found here.


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Authors: Arthur S. Long and James O. Springer

Please also feel free to contact the Gibson Dunn lawyer with whom you usually work or the following leaders and members of the Financial Institutions Group:

Arthur S. Long, Matthew L. Biben, Michael D. Bopp, Stephanie Brooker, M. Kendall Day, Michelle M. Kirschner, Jeffrey L. Steiner, James O. Springer

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