I'm told that Reg W covers transactions between "member banks" and their affiliates. Do I understand correctly that covered transactions would be between a bank and an affiliate only? Transactions between the holding company and an affiliate are not covered by the Reg if the parent company is not a bank or trust company. Right? Thanks.

I so no mention that the fact that the parent company has to be a financial institution:

Sec. 223.2 What is an “affiliate” for purposes of sections 23A and 23B and this regulation?

(a) For purposes of this part and except as provided in paragraphs (b) and (c) of this section, “affiliate” with respect to a member bank means:

(1) Parent companies. Any company that controls the member bank;