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ARTICLE · 05 OCTOBER 2010

Dodd-Frank Act Summary on Transactions with Affiliates and Insiders - Third in Series

Thompson Coburn LLP
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The Dodd-Frank Act includes several provisions that tighten the affiliate transaction rules contained in Sections 23A and 23B of the Federal Reserve Act, as well as the insider lending provisions set forth in other federal banking laws.

United StatesFinance and Banking
Peter Fanchi
Peter Fanchi
Kent Bartholomew
Kent Bartholomew
Thomas Kinsock
Thomas Kinsock
Robert LaRose
Robert LaRose
Gregory Omer
Gregory Omer
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The Dodd-Frank Act includes several provisions that tighten the affiliate transaction rules contained in Sections 23A and 23B of the Federal Reserve Act, as well as the insider lending provisions set forth in other federal banking laws. Certain of these provisions are discussed below. Your company should evaluate these changes to determine the impact on any existing or future transactions with affiliates or insiders.

Expansion of "Covered Transactions" under 23A

Section 23A defines certain types of affiliate transactions as "covered transactions," which are subject to quantitative limits and certain collateral requirements. The Dodd-Frank Act expands the definition "covered transaction" to include the following:

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