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On April 23, 2019, the Board of Governors of the Federal Reserve System approved a long-awaited proposal to revise its rules for determining whether one company has a “controlling influence” over another company for purposes of the US Bank Holding Company Act of 1956, as amended. If adopted, the proposal would represent the first material modification to the Board’s control regulations since 1984 and would bring significantly more clarity and transparency to an opaque area of the law. This Legal Update provides key takeaways from and a detailed analysis of the proposal.
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