For some banks, compliance with W-wide regulation was a particular challenge due to significant growth in capital market activity, pressure to streamline compliance and operations, changes to service models and the creation of central service centres, resolution service companies and a “surplus” of previous mergers and acquisitions. However, it is time to optimize, optimize and automate the control of affiliate transactions where possible in order to lay the groundwork for a future change in operating model. In addition, the current compliance programs of many banks may not be able to track the complexity and scale of affiliate activities and the pace of automation to report transactions, among others. In addition, enterprise-wide compliance requires a top-down program that identifies and reduces risk across the enterprise, an area in which some companies continue to face ownership, governance and policy design. Many banks have institutional-related risk and financing computer systems that must take transaction activities into account and account effectively, including affiliate identification, exemption requirements, guarantee requirements, quantitative limits and adequacy of certain service charges. An institution should provide an appropriate degree of automation that rises to its risk profile on the basis of a transaction or type of product and volume. Proper application of risk assessments would identify areas where process automation improves the efficiency and transparency of activities. Compliance with W rules can be improved by the use of technology in the following tasks: Regulation W: Key Dates Regulation W was created in 1933 with the passage of Section 23A of the Federal Reserve Act. Section 23B was then added with additional restrictions and trade qualifications. More recently, Section 608 of the Dodd-Frank Act introduced a series of significant amendments in Section 23A. The most notable change is the inclusion of derivatives and securities lending and credit transactions that justify credit risks, including pension transactions and swaps, as secure transactions. The Federal Reserve Board`s official guidance on amendments to Regulation W as a result of Section 608 has not yet been published. A decade has passed since the introduction of the Federal Reserve Regulation W, the banking rule that aims to limit certain transactions between financial institutions and their subsidiaries.
Today, regulators are paying more attention to compliance with W rules, as the greater emphasis on protecting custodians has allowed them to expect more transparency from banks, particularly with regard to the management of legal entities and intercompany transactions.