The Board of Governors of the Federal Reserve System (Board) has finalized revisions to its approach for determining whether one company has control over another for purposes of the US Bank Holding Company Act of 1956 and the Home Owners’ Loan Act, as amended. While in many respects the revisions incorporate a more transparent and predictable framework for interpreting controlling influence issues into the Board’s regulations, they also introduce new concepts and raise critical questions about how the Board will implement the approach in practice.