Federal Reserve Final Rule for Determining “Control”: Federal Reserve Adopts Final Rule Revising the “Controlling Influence” Prong of Its Control Rules

Sullivan & Cromwell LLP - January 31, 2020
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On January 30, 2020, the Board of Governors of the Federal Reserve System adopted a final rule revising the “controlling influence” prong of its “control” rules under the Bank Holding Company Act of 1956, as amended.  The Final Rule largely adopts the proposed rule, issued by the Federal Reserve in April 2019,  reaffirms the Federal Reserve’s conceptual framework for analyzing “controlling influence,” and rejects a number of banking industry recommendations for liberalization.