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When Is a Company NOT an Affiliate under Section 23A of the Federal Reserve Act and Regulation W?

calendar_today August 24, 2026 person Joseph E. Silvia domain duane-morris

Under Regulation W, the definition of “affiliate” is critical because it determines which entities trigger the quantitative limits, collateral requirements, and other restrictions of Sections 23A and 23B of the Federal Reserve Act. But not every company with a connection to your bank qualifies as an affiliate. Consider the following: A company controls a subsidiary … Continue reading “When Is a Company NOT an Affiliate under Section 23A of the Federal Reserve Act and Regulation W?”

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