under the LO Compensation rules, it defines affiliate to be "Affiliate means any company that controls, is controlled by, or is under common control with another company, as set forth in the Bank Holding Company Act of 1956 (12 U.S.C. 1841 et seq.)".

Now when I go to the Holding Company Act, I believe it defines control as one who has 25% or more ownership in the other party.

So, if you have an interest in a title company, however your ownership is only 10%, then this would not be deemed an affiliate under the new LO Compensatio Rules (226.36), correct?

We have a 3rd party saying that an affiliate would be anyone no matter what the percent of ownership would be.

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