Restrictions On Bank Affiliate Transactions: Sections 23A And 23B Of .

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Restrictions on Bank Affiliate Transactions:Sections 23A and 23B of the FederalReserve Act and Regulation WA Lexis Practice Advisor Practice Note byEric S. Yoon, Partner at K&L Gates LLPEric S. YoonThis practice note covers Sections 23A and 23B of the Federal Reserve Act (12 U.S.C. §§ 371c and 371c-1),which establish certain quantitative limits and other prudential requirements for loans, purchases of assets,and certain other transactions between a member bank and its affiliates. Regulation W (12 C.F.R. pt. 223)promulgated by the Board of Governors of the Federal Reserve System (Federal Reserve) implements Sections23A and 23B of the Federal Reserve Act.Specifically, this practice note reviews: Overview of Sections 23A and 23B of the Federal Reserve Act Who and What Are Covered by Regulation W Restrictions? Valuation and Timing Rules Applicability to U.S. Branches and Agencies of Foreign Banks Special Rules and Exemptions under Regulation W Penalties for ViolationsFor an overview of bank lending limits and related regulatory restrictions, see Lending Limits and Restrictions. Fora checklist concerning affiliate transactions and compliance with Regulation W, see Affiliate Transactions Checklistfor Insured Depository Institutions. For more information regarding Regulation W generally, see 4 RegulatoryCompliance Training Program § 5.03.Overview of Sections 23A and 23B of the Federal Reserve ActSection 23A and Section 23B of the Federal Reserve Act establish certain quantitative limits and other prudentialrequirements for loans, purchases of assets, and certain other transactions between a member bank andits affiliates. The term “member bank” includes national banks, state-chartered banks, trust companies, andinstitutions that are members of the Federal Reserve. Member banks also include state-chartered banks thatare not members of the Federal Reserve as the Federal Deposit Insurance Act as 12 U.S.C. § 1828(j) appliesSections 23A and 23B to insured state nonmember banks in the same manner and to the same extent as if theywere Federal Reserve member banks.The principal regulatory policy behind these restrictive provisions is to reduce the risk exposure of member banks,which take deposits that are insured, up to a 250,000 limit, by the Federal Deposit Insurance Corporation (FDIC)1

Restrictions on Bank Affiliate Transactions: Sections 23A and 23B of the Federal Reserve Act and Regulation Wto the balance sheet and activities of their non-FDIC-insured affiliates. The regulatory objective, in other words,is to shield the taxpayer-funded deposit insurance fund from potential losses that may result from activities ofinsured depositary institutions that may enter into transactions with their affiliates without due regard to conflicts ofinterest-related concerns.Overview of Section 23ASection 23A prohibits a bank from entering into a “covered transaction” with an affiliate if, after the transaction,(1) the aggregate amount of the bank’s covered transactions with that particular affiliate would exceed 10% ofthe bank’s capital stock and surplus, or (2) the aggregate amount of the bank’s covered transactions with all of itsaffiliates would exceed 20% of the bank’s capital stock and surplus.As more fully described in Definition of Covered Transactions below in Who and What Are Covered by RegulationW Restrictions?, covered transactions include loans and other extensions of credit to an affiliate, investments inthe securities of an affiliate, purchases of assets from an affiliate, and certain other transactions that expose thebank to the risks posed by its affiliates. A bank’s “capital stock and surplus” means the sum of the bank’s tier 1and tier 2 capital under the risk-based capital guidelines, plus the balance of the allowance for loan and leaselosses (ALLL) not included in tier 2 capital, based on the bank’s most recent Call Report. 12 C.F.R. § 223.3(d).Section 23A requires all covered transactions between a bank and its affiliate to be on terms and conditionsconsistent with safe and sound banking practices (Safety and Soundness Requirement ), subject to certainexemptions discussed below in Special Rules and Exemptions under Regulation W, and prohibits a bank frompurchasing a low-quality asset from an affiliate.A low-quality asset includes an asset that is classified or treated as “special mention” or “other transfer riskproblems” in an examination report or pursuant to the bank’s or the affiliate’s own internal asset classificationsystem, an asset in a nonaccrual status, or an asset on which payments are more than 30 days past due. Inaddition, an asset whose terms have been renegotiated or compromised as a result of the obligor’s deterioratingfinancial condition, and any asset acquired through foreclosure, repossession, or otherwise in satisfaction of adebt previously contracted that has not been satisfactorily reviewed in an examination or inspection, are includedwithin the definition of a “low-quality asset.” See 12 C.F.R. § 223.3(u).Extensions of credit to an affiliate and guarantees, letters of credit, and acceptances issued on behalf of anaffiliate (credit transactions) must be secured by a statutorily defined amount of collateral, ranging from 100%to 130% of the covered transaction amount. Securities issued by an affiliate and low-quality assets are notacceptable collateral for any credit transaction with an affiliate.Overview of Section 23BSection 23B of the Federal Reserve Act requires that certain transactions, including all covered transactions, beon market terms and conditions (Market Terms Requirement). In addition to covered transactions, the MarketTerms Requirement applies to: Any sale of assets by a bank to an affiliate Any payment of money or furnishing of services by a bank to an affiliate Any transaction in which an affiliate acts as agent or broker for the bank or any other person if the bank is aparticipant in the transaction –and– Any transaction by a bank with a third party if an affiliate has a financial interest in the third party or if theaffiliate is a participant in the transaction2

Restrictions on Bank Affiliate Transactions: Sections 23A and 23B of the Federal Reserve Act and Regulation WIn the absence of comparable transactions for identifying market terms, the bank must use terms (including creditstandards) that are at least as favorable to the bank as those that would be offered in good faith to nonaffiliatedcompanies.If you are representing a bank that is engaged in what is, or may be, a covered transaction with one of itsaffiliates, you should consider carefully on behalf of your client the Safety and Soundness Requirement, theMarket Terms Requirements, and other limitations applicable to such transaction under the Federal Reserve ActSections 23A and 23B and Federal Reserve Regulation W.As noted in Penalties for Violations below, severe civil money penalties may be imposed for violating theaforementioned provisions, not only on the bank itself but also on an “institution-affiliated party” (or IAP), as suchterm is defined under 12 U.S.C. § 1813(u), can include an attorney who knowingly or recklessly counsels, or aidsor abets, a violation.Who and What Are Covered by Regulation W Restrictions?Two threshold questions need to be answered in determining whether a transaction is subject to Federal ReserveAct Section 23A/23B and Regulation W. The first question is whether the transaction is between a bank and an“affiliate” of the bank. The second question is whether the transaction is a “covered transaction.”Definition of “Affiliate”Regulation W applies to covered transactions between a bank and a bank affiliate. The definition of affiliate forpurposes of Regulation W, set forth in Section 223.2, is broad, and includes: Any company that controls the bank Any company that is controlled by a company that controls the bank Any company that is controlled, directly or indirectly, by or for the benefit of shareholders who beneficially orotherwise control, directly or indirectly, by the bank or any company that controls the bank Any company, including a real estate investment trust, that is sponsored and advised on a contractual basisby the bank or an affiliate of the bank Any registered investment company for which the bank or any affiliate of the bank serves as an investmentadviser Any unregistered investment fund for which the bank or any affiliate of the bank serves as an investmentadviser, if the bank and its affiliates own or control in the aggregate more than 5% of any class of votingsecurities or more than 5% of the equity capital of the fund Note that private equity funds, foreign investment funds, and commodities funds that currently escapetreatment as an affiliate because they are not registered under the Investment Company Act of 1940(1940 Act) may be covered under this definition. (The Federal Reserve is of the stated view that theadvisory relationship of a bank or affiliate with an investment fund presents the same potential for conflictsof interest, regardless of whether the fund is an investment company registered with the Securities andExchange Commission (SEC) under the 1940 Act). An insured depository institution that is a subsidiary of the bank A financial subsidiary of the bank Any subsidiary of the bank that is an employee stock option plan or similar entity established for the benefit ofthe shareholders, partners, members, or employees of the bank or an affiliate of the bank3

Restrictions on Bank Affiliate Transactions: Sections 23A and 23B of the Federal Reserve Act and Regulation W Any subsidiary of the bank, if affiliates (other than insured depository institution affiliates) or controllingshareholders of the bank also control the subsidiary through a nonbank chain of ownership Subject to certain safe harbors, any portfolio company in which a holding company of the bank owns orcontrols, directly or indirectly, or through one or more other persons, 15% or more of the equity capital of thecompany under the merchant banking or insurance company investment authority of the Financial ServicesModernization Act of 1999, also known as the Gramm-Leach-Bliley Act (GLBA) Any partnership for which the bank or any affiliate of the bank serves as general partner or for which the bankor affiliate causes any director, officer, or employee to serve as general partner Any subsidiary of an affiliate of the bank –and– Any company that the Federal Reserve (or other appropriate federal banking agency) determines to havea relationship with the bank or an affiliate of the bank such that covered transactions by the bank with thecompany may have a detrimental effect on the bankDefinition of “Covered Transaction”Once a determination has been made that a bank indeed proposes to enter into a transaction with an affiliate,then the next step is to see whether the transaction is covered under Section 23A or 23B and under Regulation W.Under Section 223.3(h) of Regulation W, a covered transaction includes: An extension of credit to an affiliate A purchase of, or investment in, a security issued by an affiliate A purchase of an asset from an affiliate, including an asset subject to recourse or an agreement to repurchase The acceptance of a security issued by an affiliate as collateral for an extension of credit to any person orcompany –and– The issuance of a guarantee, acceptance, or letter of credit, including an endorsement or standby letter ofcredit, on behalf of an affiliate; a confirmation of a letter of credit issued by an affiliate; and a cross-affiliatenetting arrangement (cross-affiliate netting arrangements are defined in Section 223.3(j) of Regulation W asarrangements among a bank, one or more affiliates of the bank, and one or more nonaffiliates, where thenonaffiliate is permitted to deduct obligations of the affiliate to the nonaffiliate in settling its obligations to thebank, or a bank is required or permitted to add affiliate obligations to a nonaffiliate when determining thebank’s total obligations to the nonaffiliate)An extension of credit to an affiliate is broadly defined in Section 223.3(o) of Regulation W as the making orrenewal of a loan, the granting of a line of credit, or the extending of credit in any manner whatsoever (examplesinclude advance to an affiliate by means of an overdraft, cash item, or otherwise; a sale of federal funds to anaffiliate; a lease that is the functional equivalent of an extension of credit to an affiliate; an acquisition by purchase,discount, exchange, or otherwise of a note or other obligation, including commercial paper or debt securities, ofan affiliate; any increase in the amount of, extension of the maturity of, or adjustment to the interest rate term orother material term of an extension of credit to an affiliate; and any other similar transaction as a result of whichan affiliate becomes obligated to pay money or its equivalent), including on an intraday basis, to an affiliate.A bank’s purchase of a debt security issued by an affiliate is an extension of credit by the bank to the affiliate forpurposes of Section 23A. “Keepwell” agreements, under which a bank commits to maintain the capital levels orsolvency of an affiliate, also are considered guarantees for purposes of Federal Reserve Act Section 23A and4

Restrictions on Bank Affiliate Transactions: Sections 23A and 23B of the Federal Reserve Act and Regulation WRegulation W. The regulatory presumption here is that credit risk incurred by the bank in such arrangements issimilar to the risk incurred by the bank when it issues a guarantee on behalf of an affiliate.Valuation and Timing RulesSections 223.21 through 223.24 of Regulation W set forth valuation and timing rules that are designed todetermine the amount of a covered transaction subject to the quantitative limitations and collateral requirementsof the rule and the time at which a transaction becomes subject to such limitations and requirements.Valuation Rules for Credit TransactionsCredit transactions with affiliates generally are valued at the greatest of: The principal amount of the transaction The amount owed by the affiliate to the bank under the transaction –and– The sum of the amount provided to, or on behalf of, the affiliate in the transaction and any additional amountthe bank could be required to provide to, or on behalf of, the affiliate under the terms of the transactionThe value of a loan to an affiliate purchased by the bank from a nonaffiliate is the total amount of considerationgiven by the bank in exchange for the loan and any additional amount the bank could be required to provide to, oron behalf of, the affiliate. Although a bank’s purchase of, or investment in, a debt security issued by an affiliate isconsidered an extension of credit to the affiliate, these transactions are not valued like other extensions of credit.Purchases of, or investments in, securities issued by an affiliate are valued at the greater of the bank’s purchaseprice or the carrying value of the securities.Special Timing Rules for Credit TransactionsA bank is deemed to enter into a credit transaction with an affiliate at the time during the day that the bankbecomes legally obligated to enter into the transaction, not at the end of the day on which the loan agreement issigned or the loan is funded. Credit transactions with nonaffiliates generally become covered transactions whenthe nonaffiliate becomes an affiliate of the bank. If the nonaffiliate becomes an affiliate within one year after thebank has entered into the credit transaction with it, the bank must ensure that the collateral requirements ofRegulation W are met “promptly” after the nonaffiliate becomes an affiliate. In all cases, the transaction must meetthe Market Terms Requirement. However, leeway provided by the promptly standard is not available if the credittransaction is made in contemplation of the nonaffiliate becoming an affiliate of the bank.Loans Secured by Affiliate SecuritiesLoans by a bank to a third party that are secured exclusively by affiliate securities are valued at the lesser of: The total amount of the extension of credit –and– The fair market value of the pledged affiliate securities, if they have publicly available price quotesOn the other hand, loans by a bank to a third party that are secured by both affiliate and nonaffiliate securities arevalued at the lesser of: The total amount of the extension of credit, minus the fair market value of nonaffiliate collateral –and– The fair market value of the pledged affiliate securities, if they have publicly available price quotes (Under this5

Restrictions on Bank Affiliate Transactions: Sections 23A and 23B of the Federal Reserve Act and Regulation Wvaluation rule, the maximum amount that the bank must count against Regulation W’s quantitative limits is thedifference between the full amount of the loan and the fair market value of the nonaffiliate collateral.)Securities of an eligible affiliated mutual fund are not considered securities issued by an affiliate for purposesof this valuation rule, subject to certain conditions designed to ensure liquidity and minimize the use of theexemption as a method of funding affiliates.Eligible affiliated mutual fund securities are securities issued by an open-end investment company registered withthe SEC under the 1940 Act if both of the following are true: The securities have publicly available price quotes. The bank and its affiliates do not own more than 5% of the fund’s shares, excluding shares held in good faithin a fiduciary capacity.Furthermore, the bank may not exclude affiliated mutual fund securities if it knows, or has reason to know, that theproceeds of the extension of credit will be used to purchase the affiliated mutual fund shares serving as collateralor otherwise will be used to benefit an affiliate.Valuation Rules for Purchases of Assets from an AffiliatePurchases of assets by a bank from an affiliate generally are valued at the total consideration given, includingliabilities assumed, by the bank in exchange for the asset. The value may be reduced after the purchase to reflectamortization or depreciation of the asset, consistent with GAAP.Regulation W provides a special valuation rule for a bank’s purchase of a line of credit or loan commitmentfrom an affiliate. A bank must value such an asset at the purchase price paid, plus any additional amount thatthe bank is obligated to provide under the credit facility. Without this special rule, a company would be able totransfer substantial amounts of unfunded obligations to its affiliated bank without being subject to Section 23A’squantitative limitations.Valuation Rules for Purchases of or Investments in Affiliate SecuritiesAs noted above, purchases of or investments in securities issued by an affiliate are valued at the greater of thebank’s purchase price or carrying value of the securities. This approach reflects the risk of continuing exposureto an affiliate through an investment in securities, even if that investment was made at a price below the carryingvalue of the securities. On the other hand, if the carrying value of the investment declines below the purchaseprice as the affiliate’s financial condition worsens, the rule limits the ability of the bank to provide additionalfunding as the affiliate approaches insolvency.A bank may acquire securities of an affiliate in a transaction that results in the affiliate becoming an operatingsubsidiary of the bank. These transactions are treated as a purchase of assets and assumption of liabilities ofan affiliate. The covered transaction amount for these transactions is the total amount of consideration given bythe bank for the shares, plus the total liabilities of the transferred company. The value of the covered transactionmay be subsequently reduced to reflect amortization or depreciation of the assets of the transferred companyconsistent with GAAP, and sales of assets of the transferred company.6

Restrictions on Bank Affiliate Transactions: Sections 23A and 23B of the Federal Reserve Act and Regulation WVarious Limitations and RequirementsQuantitative LimitationsA bank may not engage in a new covered transaction with an affiliate if the aggregate amount of coveredtransactions between the bank and the affiliate would be in excess of 10% of the bank’s capital stock and surplusafter consummation of the new transaction. Aggregate covered transactions between the bank and all affiliatesare limited to 20% of the bank’s capital stock and surplus.Consistent with GLBA, transactions between a bank and a financial subsidiary of the bank are not subject tothe 10% limitation. This exemption from the 10% limit applies to investments by the bank in its own financialsubsidiaries. Investments by the bank in the financial subsidiaries of affiliated depository institutions are subjectto the 10% limitation. Aggregate covered transactions with all financial subsidiaries and other affiliates of the bankare subject to the 20% limitation.Consistent with existing interpretations of Section 23A, Regulation W does not require the unwinding oftransactions if a bank’s capital declines such that the 10% or 20% quantitative limitation is exceeded. However,new transactions would be forbidden until the quantitative limits could be met.Collateral RequirementsAny credit transaction between a bank and its affiliate must be secured with the statutorily required amount ofcollateral.Under Section 223.14 of Regulation W: A credit transaction must be secured by collateral having a market value equal to at least: 100% of the amount of the transaction if the collateral is:–– Obligations of the United States or its agencies–– Obligations fully guaranteed by the United States or its agencies as to principal and interest–– Notes, drafts, bills of exchange, or bankers’ acceptances that are eligible for rediscount or purchaseby a Federal Reserve Bank –or––– A segregated, earmarked deposit account with the bank that exists for the sole purpose of securingcredit transactions between the bank and its affiliates and is identified as such 110% of the amount of the transaction if the collateral is obligations of any state or political subdivisionthereof 120% of the amount of the transaction if the collateral is other debt instruments, including loans or otherreceivables 130% of the amount of the transaction if the collateral is stock, leases, or other real or personal property The following types of collateral are ineligible collateral under Regulation W: Low-quality assets Securities issued by any affiliate Equity securities issued by the bank and debt securities issued by the bank that represent regulatorycapital of the bank7

Restrictions on Bank Affiliate Transactions: Sections 23A and 23B of the Federal Reserve Act and Regulation W Intangible assets, unless specifically approved by the Federal Reserve Guarantees, letters of credit, and similar instrumentsIn addition, a bank must maintain a perfected security interest in collateral securing credit transactions. Thesecurity interest must be enforceable under applicable law, including in the event of bankruptcy or similar default.If the bank does not have a first priority security interest in the collateral, it must deduct from the value of thecollateral the lesser of: The amount of any security interest in the collateral that is senior to the bank’s interest –or– The amount of credit secured by the collateral that is senior to the bank’s position (any retired or amortizedcollateral must be replaced with additional eligible collateral over the life of the credit transaction)Note that some transactions are exempt from the collateralization requirements. These include: An acceptance that is already fully secured either by attached document, or other property with anascertainable market value that is involved in the transaction The unused portion of an extension of credit to an affiliate if the bank does not have any legal obligation toadvance additional funds until required collateral is posted –and– Purchases of affiliate debt securities by the bank from a nonaffiliate in a bona fide secondary markettransactionApplicability to U.S. Branches and Agencies of Foreign BanksSection 223.61 of Regulation W applies Sections 23A and 23B only to transactions between a U.S. branchor agency of a foreign bank and affiliates of the branch or agency engaged directly in the United States in thefollowing activities: full-scope securities underwriting and dealing, non-credit-related insurance underwriting,merchant banking, and insurance company investments. Regulation W also applies Sections 23A and 23B totransactions between a U.S. branch or agency of a foreign bank and any portfolio company controlled by theforeign bank under GLBA’s merchant banking or insurance company investment authorities. Regulation W doesnot apply to transactions between a U.S. branch or agency of a foreign bank and other affiliates or to transactionsbetween the foreign bank’s non-U.S. offices and its U.S. affiliates.Special Rules and Exemptions under Regulation WSpecial Rules for Derivatives TransactionsUnder Section 223.33 of Regulation W, a bank must establish policies and procedures reasonably designed tomanage the credit exposure arising from its derivatives transactions with each affiliate and all affiliates in theaggregate. Specifically, the policies and procedures must at a minimum provide for: Monitoring and controlling the credit exposure arising at any one time from the bank’s derivatives transactionswith each affiliate and all affiliates in the aggregate Ensuring that the bank’s derivatives transactions comply with the Market Terms Requirement of Section 23BIn particular, a bank must: Have in place credit limits on its derivatives exposures to affiliates that are at least as strict as those imposedon unaffiliated companies engaged in similar businesses and substantially equivalent in size and credit quality8

Restrictions on Bank Affiliate Transactions: Sections 23A and 23B of the Federal Reserve Act and Regulation W Monitor its derivatives exposure to affiliates in a manner at least as rigorous as used to monitor exposure tocomparable unaffiliated companies –and– Price, and require collateralization of, affiliate derivatives transactions in a way that is at least as favorable tothe bank as pricing and collateralization of unaffiliated transactionsMonitoring and controlling the credit exposure from derivatives transactions includes, at a minimum, imposingappropriate credit limits, mark-to-market requirements, and collateral requirements. The limits and requirementsimposed by a bank should reflect the nature, volume, and complexity of its derivatives transactions, and should beapproved by the board of directors of the bank or an appropriate board committee.Under Section 223.33(c) of Regulation W, a credit derivative between a bank and a nonaffiliate in which the bankprovides credit protection to the nonaffiliate with respect to an obligation of an affiliate of the bank is considereda “guarantee” by a bank on behalf of an affiliate and, as such, would be a covered transaction. Such derivativesinclude: An agreement under which the bank, in exchange for a fee, agrees to compensate the nonaffiliate for anydefault of the underlying obligation of the affiliate; and An agreement under which the bank, in exchange for payments based on the total return of the underlyingobligation of the affiliate, agrees to pay the nonaffiliate a spread over funding costs plus any depreciation inthe value of the underlying obligation of the affiliateSpecial Rules for Financial SubsidiariesRegulation W treats financial subsidiaries of a bank as affiliates of the bank, in contrast to the general treatmentof subsidiaries of a bank as nonaffiliates. A financial subsidiary is any subsidiary of a national or state bank thatengages in activities (whether as principal or agent) not permissible for national banks to conduct directly.Regulation W exempts from the definition of a financial subsidiary a subsidiary of a state bank that engages onlyin activities permissible for the state bank to conduct directly or activities lawfully conducted prior to December12, 2002, the date of publication of final Regulation W. However, neither of these exemptions is available fora financial subsidiary of a state bank that engages in principal activities that GLBA requires a national bank toconduct in a financial subsidiary. For example, a subsidiary of a state bank that is underwriting and dealing inbank-ineligible securities would be a financial subsidiary.A bank’s investment in securities issued by its own financial subsidiary is valued at the greater of: The total amount of consideration given by the bank in exchange for the security –and– The carrying value of the security as of the date of acquisition (The carrying value of the bank’s investment forpurposes of this valuation rule is not adjusted going forward for any earnings retained or losses incurred bythe subsidiary after the bank’s investment.)Exemptions from the Attribution RuleRegulation W provides certain exemptions (which are described below) from the general rule that treats atransaction with any person as an affiliate transaction to the extent that the proceeds of the transaction are usedfor the benefit of, or transferred to, an affiliate. Notwithstanding these exemptions, these transactions are subjectto the Safety and Soundness and Market Terms Requirements of Regulation W.9

Restrictions on Bank Affiliate Transactions: Sections 23A and 23B of the Federal Reserve Act and Regulation WExemption from the Attribution Rule for General Purpose Credit CardsSection 223.16(c) of Regulation W exempts from the attribution rule an extension of credit to a n

within the definition of a "low-quality asset." See 12 C.F.R. § 223.3(u). Extensions of credit to an affiliate and guarantees, letters of credit, and acceptances issued on behalf of an affiliate (credit transactions) must be secured by a statutorily defined amount of collateral, ranging from 100% to 130% of the covered transaction amount.

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