The Federal Reserve Board, the FDIC and the OCC (collectively, the "agencies") extended previously issued no-action relief to asset managers and other institutions from certain regulations that limit extensions of credit to "insiders."

Regulation O ("Loans to Executive Officers, Directors, and Principal Shareholders of Member Banks") establishes quantitative limits and qualitative restrictions on extensions of credit by depository institutions to "insiders" (i.e., executive officers, directors, and principal shareholders and affiliates).

The new relief rescinds and supersedes the agencies' previous extension of the no-action relief (see previous coverage). The relief, previously set to expire on January 1, 2022, will now expire on the earlier of (i) January 1, 2023, or (ii) the effective date of a final rule by the FRB that revises Regulation O with respect to "treatment of extensions of credit by a bank to fund complex-controlled portfolio companies that are insiders of the bank."

Primary Sources

1. Extension of the Revised Statement Regarding Status of Certain Investment Funds and their Portfolio Investments for Purposes of Regulation O and Reporting Requirements under Part 363 of FDIC Regulations

2. SR 21-20: Status of Certain Investment Funds and their Portfolio Investments for Purposes of Regulation O and Reporting Requirements under Part 363 of FDIC Regulations