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    Home /  Insights /  Articles And Books /  Article
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    Rodge Cohen, Michael Escue and Amy Dreisiger Author Law360 Article on Proposed Update to CIBCA

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    October 24, 2024

    S&C Senior Chair Rodge Cohen, Financial Services Group Partner Michael Escue and associate Amy Dreisiger co-authored an article for Law360 discussing the adoption of proposed rulemaking to amend the FDIC’s regulations under the Change in Bank Control Act of 1978.

    According to the authors, the implications of this proposal could be substantial given the potential uncertainty around investments by mutual fund complexes in banking organizations. These investments are a critical and stable source of capital for the banking industry and with this change, “[t]he FDIC is asserting approval authority over not only investments by mutual fund complexes, at which the proposal is apparently directed, but also by all investors.”

    Further developments on this issue are expected, including comments on the notice of proposed rulemaking, due in late November.

    Read: “What FDIC Expansion of Change in Bank Control Could Mean” 

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    H. Rodgin Cohen Headshot Photo
    H. Rodgin Cohen
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    Michael T. Escue Headshot Photo
    Michael T. Escue
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    Amy R. Dreisiger Headshot Photo
    Amy R. Dreisiger
    New York
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