Posted by Andrew R. Gladin, Sullivan & Cromwell LLP, on Saturday, February 6, 2016
Editor's Note: This post is based on a Sullivan & Cromwell LLP publication authored by Andrew R. Gladin, Mark J. Welshimer, and Sarah C. Flowers. The complete publication, including Annexes, is available here.
On January 21, 2016, the Federal Reserve published in the Federal Register a final rule (the “Final Rule”) [1] modifying Forms FR Y-14A, FR Y-14Q and FR Y-14M (collectively, the “FR Y-14 Forms”). Most notably, the Final Rule requires the chief financial officer (“CFO”) of each bank holding company (“BHC”) that is overseen by the Federal Reserve’s Large Institution Supervision Coordinating Committee (the “LISCC Firms”) and that reports on the FR Y-14 Forms to make attestations regarding those forms and to “agree to report material weaknesses and any material errors in the data” reported on those forms.