Does anyone know where I could find a good summary of Reg. W? I've looked through BOL and was unable to find anything other than links to the Federal Register.

What do think Reg W should be? There's isn't a W as of this afternoon. Maybe we could help if we knew what you were trying to find.

http://www.goodwinprocter.com/fsas/FSA_11_05_02.pdf
This is a summary on a law firm's site...may or may not be the detail you want.

Hey Anonymous - get with the program will ya. Be careful before you berate someone for asking a question - you might get the V2 award if we could identify you.

"W" is a consolidation of 23A and B and interpretations thereof.

Maria asked the same question recently and Ted gave a succinct answer here.

Thanks everyone for your help.

The thank-you was from me--I forgot to sign on.

From today's ABA Newsbytes:

REG W EXPLAINED
The Federal Reserve's new Regulation W puts into effect sections 23A and 23B of the Federal Reserve Act. The comprehensive regulation, which takes effect April 1, includes 70 years' worth of interpretive guidance furnished by the Fed. Many of the provisions concern statutory requirements that are fairly brief but extremely complex in application. For that reason, the Fed recently published SR 03-2, a letter that summarizes how it resolved nine significant issues addressed by the final rule. These include derivatives, intraday credit, financial subsidiaries, and more. Read SR 03-2 at http://www.federalreserve.gov/boarddocs/srletters/2003/sr0302.htm

In reading the new regulation I want to clarify an issue. We have a bank affiliate (same holding company). We purchase loans from them and vice versa if they exceed our legal lending limits. I know these are covered transactions. It looks as though we are limited to 10% of our Capital and the loan must be collateralized by 130 percent of the amount of the transaction if secured by anything other than T-bills, debt instruments, etc. (i.e. real estate, equipment, etc). Am I correct?

I haven't read it yet as it isn't generally a reg I have to address as much as HMDA and CRA right now. But these transaction it is after should be obligations of the bank, not the sale of loans. 23A and B didn't effect these to my knowledge.

Does No. 6 help?

6. Section 250.250 Exemption. Since 1974, a bank's purchase of loans from an affiliate has not been subject to section 23A if (i) the bank makes an independent evaluation of the creditworthiness of the borrower before the affiliate makes the loan, and (ii) the bank commits to purchase the loan prior to the affiliate making the loan (the "250.250 exemption"). The purpose of the exemption was to allow a bank to take advantage of an investment opportunity and not to alleviate the funding needs of an affiliate. By the 1990s, however, some banks were using this exemption to provide nearly all their non-bank lending affiliates' funding. In 1995, to ensure that banks used the 250.250 exemption consistently with its original purpose, Board staff opined that the exemption was not available to any bank whose loan purchases from an affiliate represented more than 50 percent of the loans made by the affiliate.

The final rule retains the 50 percent test as a general matter but allows the bank's primary federal regulator to reduce the 50 percent threshold prospectively, on a case-by-case basis, if appropriate to protect the safety and soundness of the bank. Concurrent with the adoption of the final Regulation W, the Board is seeking comment on a proposed rule that would limit a bank's purchases of extensions of credit from an affiliate under the exemption to 100 percent of the bank's capital stock and surplus.