On September 30, 2020, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) issued four Frequently Asked Questions (the “FAQs”) with respect to the Federal Reserve’s final rule on controlling influence adopted on January 30, 2020, which became effective today (the “Final Rule”). Our Memorandum to Clients, published on January 31, 2020, discusses the Final Rule in detail. The FAQs relate to: (1) the mechanics of the Final Rule’s total equity formula; (2) clarification that the Federal Reserve would not require alterations to investment structures that predate the Final Rule and that represent a reasonable interpretation of the Federal Reserve’s precedent at the time the investment was made; (3) clarification that a contractual provision that provides a first company with a reasonable and non-punitive mechanism to redeem, reduce, or restructure its investment in the second company if the second company fails to conform its activities to activity restrictions of the Bank Holding Company Act or Home Owners’ Loan Act generally would not be considered a “limiting contractual right”; and (4) Analysis of market standard loan covenants as “limiting contractual rights”.