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ARTICLE · 29 JANUARY 2007

"Let’s Form A Committee"— Issues Facing Financial Institutions In Implementing The Latest Guidance On Complex Structured Finance Transactions

Pillsbury Winthrop Shaw Pittman
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On January 5, the four federal depository institution supervisors and the Securities and Exchange Commission published their Interagency Statement on Sound Practices Concerning Elevated Risk Complex Structured Finance Activities (Interagency Statement). A hyperlink to the Interagency Statement appears at the end of this advisory.

United StatesFinance and Banking
Ernest Patrikis
Ernest Patrikis
Glen Cuccinello
Glen Cuccinello

On January 5, the four federal depository institution supervisors and the Securities and Exchange Commission published their Interagency Statement on Sound Practices Concerning Elevated Risk Complex Structured Finance Activities ("Interagency Statement"). A hyperlink to the Interagency Statement appears at the end of this advisory.

The stated intent of the agencies in issuing the Interagency Statement is to help financial institutions in identifying complex structured finance transactions ("CSFTs") that may pose heightened legal or reputational risks to the institution ("elevated risk CSFTs") and in evaluating, managing and addressing those risks within the institutions’ internal control frameworks. The agencies cite as examples of elevated risk CSFTs those in which the customer’s regulatory, tax, or accounting treatment for the CSFT, or disclosures to investors concerning the CSFT in the customer’s public filings or financial statements, do not comply with applicable laws,

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