Affiliate Transactions

The drama around yesterday's Fed decision to grant Morgan Stanley a 23A exemption makes the exemption a tempting target for criticism. But a minor factual error in Governor Bowman's statement defending the decision reveals critical context that puts the decision in perspective. In case you missed it, the Fed Board voted 4-3 to approve an exemption letting Morgan Stanley move a significant trading operation from its European non-bank subsidiary to its US FDIC-insured bank. Such a transaction would usually be prohibited by the restrictions on bank transactions with their affiliates in the...

BJ Sanford advises payments and fintech companies, U.S. and foreign banks, trade associations, investors, and policy and consulting firms. His practice centers on payments regulation, public policy, and the regulation of bank activities and structure. He also advises clients on regulatory capital, bank investments and control, affiliate transactions, the U.S. operations of foreign banks, and regulatory examinations. Payments regulation. BJ advises payments firms and banks on payment regulation, product development, and compliance with rules including Regulation E, Regulation Z, Regulation II...

Ray Natter advises on bank regulatory matters, including bank structure, securities and corporate practices, and legislative affairs. He brings experience from the OCC, the Federal Reserve Board, and the Senate Banking Committee, and is recognized as one of the leading experts in financial services law. Ray served as deputy chief counsel of the Office of the Comptroller of the Currency from 1995 through 2004, where his responsibilities included the development and review of all of the agency's regulatory undertakings; at the OCC he also led the legal department's securities and corporate...