Dodd-Frank and Reconsidering Financial Holding Company Status


Section 606 of the Dodd-Frank Act adds a new standard for a bank holding company (BHC) which elects to become, or already is, a financial holding company (FHC). Now, in order for a BHC to elect or maintain FHC status, not only must a BHC certify that its bank subsidiaries are well capitalized and well managed and have satisfactory CRA ratings, but the BHC itself must be deemed well capitalized and well managed.

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