Does a bank have to monitor entities such as 401(k) participants under 314a if the bank is managing the 401(k)) or shareholders/bondholders (if the bank is the transfer agent for the equity issuance or bond indenture). My inclination is no, since 31 C.F.R. 1010.505(d)(2) excludes any transaction conducted through an account.
Thank for any thoughts on this.
Last edited by komply1; 10/15/18 05:10 PM.
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