The Board of Governors of the Federal Reserve (the "Federal Reserve") has over several decades defined when an activity engaged in by foreign banks subject to the Bank Holding Company Act of 1956 (the "BHCA"), which are thus...more
On November 23, 2021, the Chief Counsel and Senior Deputy Comptroller Benjamin W. McDonough of the Office of the Comptroller of the Currency (the "OCC") issued OCC Interpretive Letter 1179 (dated November 18, 2021) ("IL...more