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Pledging Collateral for Affiliate Borrowings: A “Guarantee” in Disguise under Reg W?

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

Sometimes a guarantee does not look like a traditional guarantee. Consider the following: a bank pledges its own collateral to secure a borrowing made by an affiliate from a third-party lender. Is this a guarantee by the bank on behalf of the affiliate?

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