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Federal Reserve Anti-Tying Leveraged Loans

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review - April 15, 2013

Fed Proposal on Annual Assessments - On April 15, the Fed requested comment on a proposed rule to establish an annual assessment for bank holding companies and savings and loan companies with $50 billion or greater in total...more

Orrick, Herrington & Sutcliffe LLP

Multi-Agency Guidance on Leveraged Lending Practices

On March 21, 2013, the Office of the Comptroller of the Currency (“OCC”), the Board of Governors of the Federal Reserve System (“Federal Reserve”) and the Federal Deposit Insurance Corporation (“FDIC”) (collectively, the...more

Orrick, Herrington & Sutcliffe LLP

Did an obscure remark in a recent regulatory publication signal a new interpretation of the anti-tying rules?

As discussed in this Orrick alert, federal bank regulators recently issued guidance to financial institutions concerning leveraged lending practices (the “Lending Guidance”). In most respects the Lending Guidance was...more

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