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On December 22, 2020, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation (FDIC) issued their Revised Statement Regarding Status of Certain Investment Funds and Their Portfolio Investments for Purposes of Regulation O and Reporting Requirements under Part 363 of FDIC Regulations, which supersedes and replaces their earlier joint statement that was set to expire on January 1, 2021. This Legal Update provides further detail and analysis.

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