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Guarantees and Letters of Credit: Understanding “On Behalf Of” Under Regulation W

calendar_today October 15, 2026 person Joseph E. Silvia domain duane-morris

One of the “covered transaction” categories under Section 23A of the Federal Reserve Act and Regulation W is the issuance of a guarantee or letter of credit by a bank “on behalf of an affiliate.” But what exactly does ‘on behalf of’ mean here? The Federal Reserve has clarified that a guarantee or letter of … Continue reading “Guarantees and Letters of Credit: Understanding “On Behalf Of” Under Regulation W”

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