On September 8, 2016, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation released a report on the activities and investments that banking entities may engage in under US state and federal law (the “Report”). The Report includes several recommendations for limitations on those activities and investments that, if fully implemented, would have a significant impact on many domestic and international banking organizations, particularly larger ones. This Legal Update discusses the Report’s principal recommendations and the likely timing of their implementation, as well as insights from the Report on how the agencies view and are likely to treat certain activities.
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