Affiliate Transactions (Regulation W)

Section 23A of the Federal Reserve Act (12 USC 371c) is the primary statute governing transactions between a bank and its affiliates. Section 23A (1) designates the types of companies that are affiliates of a bank; (2) specifies the types of transactions covered by the statute; (3) sets the quantitative limitations on a bank’s covered transactions with any single affiliate, and with all affiliates combined; and (4) sets forth collateral requirements for certain bank transactions with affiliates.

Policy Letters

Affiliate Transactions (Regulation W)

Addendum to the Interagency Policy Statement on Income Tax Allocation in a Holding Company Structure

Interagency Policy on Banks/Thrifts Providing Financial Support to Funds Advised by the Banking Organization

Adoption of Regulation W Implementing Sections 23A and 23B of the Federal Reserve Act

Section 20 subsidiaries--Impact on Inspections Resulting from the Replacement of "Firewalls" with Operating Standards

Additional Resources

Manual References

  • Bank Holding Company Supervision Manual (Sections 2020.0 – 2020.7 and 2020.9)
    • Section 2020.0, "Intercompany Transactions–Introduction"
    • Section 2020.1, "Intercompany Transactions (Transactions Between Member Banks and Their Affiliates–Sections 23A and 23B of the Federal Reserve Act)"
  • Commercial Bank Examination Manual
    • Section 6070.1, "Transactions Between Member Banks and Their Affiliates"
    • Section 6072.1, "Bank-Related Organizations"
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Last Update: October 03, 2023