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    FED Extends Information Collection on Structured Finance Activities

    September 11, 2019

    FED extended for three years, without revision, the recordkeeping provisions associated with the Interagency Statement on complex structured finance activities. No required reporting forms are associated with the recordkeeping provisions that are part of the information collection FR 4022. The final notice for this extension was published in the Federal Register on August 13, 2019. FED also published the updated OMB supporting statement (OMB No. 7100-0311) for these recordkeeping provisions.

    This annual information collection is relevant for state member banks, bank holding companies (other than foreign banking organizations), savings and loan holding companies, and U.S. branches and agencies of foreign banks, with the estimated number of respondents being 18. The guidance associated with these recordkeeping provisions provides that these FED-supervised institutions should establish and maintain policies and procedures for identifying, evaluating, assessing, documenting, and controlling risks associated with certain complex structured finance transactions. These policies and procedures should address the full range of credit, market, operational, legal, and reputational risks associated with such transactions. The guidance states that supervised entities should provide sufficient information and convey reports to the institution's management and board of directors concerning elevated risks from the complex structured finance transactions. A financial institution operating in foreign jurisdictions may tailor its policies and procedures as appropriate to account for, and comply with, the applicable laws, regulations, and standards of those jurisdictions.

    FED, on May 15, 2019, had published an initial notice in the Federal Register requesting public comment for 60 days on the extension, without revision, of the information collection FR 4022. The comment period for this notice had expired on July 15, 2019 and FED did not receive any comments. The published OMB Statement includes a number of collections of information, each of which is voluntary.

     

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    Keywords: Americas, US, Banking, Information Collection, Structured Finance, FR 4022, FED

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