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Summary:

The Federal Reserve Board (FRB), the Federal Deposit Insurance Corporation (�౦��Ϸ����), and the Office of the Comptroller of the Currency (OCC) (together “federal banking agencies”) are issuing the attached revised interagency statement, concerning Regulation O and Part 363 of the �౦��Ϸ����’s Regulations, to extend the expiration of certain no-action relief previously provided in an interagency statement accompanying FIL 85-2019, dated December 27, 2019, and to clarify eligibility criteria for such relief.

Statement of Applicability to Institutions with Total Assets under $1 Billion: This Financial Institution Letter applies to all �౦��Ϸ����-supervised institutions.

Highlights:

• On December 27, 2019, the federal banking agencies issued temporary no-action relief to provide time for the FRB, in consultation with the other federal banking agencies, to consider whether to amend Regulation O to address concerns about unintended consequences of the application of Regulation O to companies that sponsor, manage, or advise investment funds and institutional accounts that invest in voting securities of banking organizations.
• The revised interagency statement extends the expiration of the no-action relief until January 1, 2022, and clarifies the eligibility criteria for such relief.
• This FIL supersedes and rescinds FIL 85-2019, dated December 27, 2019.

Suggested Distribution:

�౦��Ϸ����-supervised institutions

Suggested Routing:

Board of Directors
Chief Executive Officer
Chief Financial Officer
Chief Operating Officer
Chief Risk Officer