ARTICLE
11 October 2019

Agencies To Raise Asset Thresholds For Management Interlock Rules

CW
Cadwalader, Wickersham & Taft LLP

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Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
The Office of the Comptroller of the Currency, the Federal Reserve Board and the FDIC (collectively, the "agencies") adopted a final rule to increase the major asset
United States Finance and Banking

The Office of the Comptroller of the Currency, the Federal Reserve Board and the FDIC (collectively, the "agencies") adopted a final rule to increase the major asset prohibition thresholds for management interlock rules. The final rule is unchanged since its December 2018 introduction.

The Depository Institution Management Interlocks Act major assets prohibition generally bars a management official of a depository organization with $2.5 billion in total assets from serving simultaneously as the management official of an unaffiliated depository organization with more than $1.5 billion in total assets. Under the final rule, both total asset thresholds would be raised to $10 billion.

The final rule will become effective upon the date of its publication in the Federal Register.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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