Banking Report Index-Summary

S&Ls

See SAVINGS AND LOAN ASSOCIATIONS (S&Ls)

SAN MARINO

– Credito Industriale Sammarinese, Italian bank regulators replace director during tax haven crackdown, 95:897

SARBANES-OXLEY ACT

– Executive compensation clawback provisions, no allegations of wrongdoing on part of corporate executives necessary for SEC pursuit of reimbursement (D. Ariz.), 94:1196
– Internal auditor for Morgan Stanley's credit card subsidiary, complaint protected (DOL ARB), 94:330
– Separation of powers doctrine, provision on “for cause” removal of PCAOB members unconstitutional (U.S., aff in part, rvs in part), 95:22

SAVINGS AND LOAN ASSOCIATIONS (S&Ls)

– Earnings, OTS report, fourth quarter 2009, 94:407
– Oversight, future uncertain with OTS merger into OCC and implementation of Dodd-Frank Act rules, 95:912

SAVINGS RATE

– Automatic individual accounts, CFA and Financial Servs. Roundtable joint project for low- and moderate-income families, 94:368
– Recession, impact on U.S. families' savings goals, Consumer Fed'n of Am. survey, 94:421

SEC

See SECURITIES AND EXCHANGE COMMISSION (SEC)

SECURITIES

– Argentine assets, immunity from claims by hedge funds and other investors (U.S., rev den), 94:483; request for advice on state law requirements (2d Cir.), 95:525
– Asset-backed securities

– – Risk management, FRB report on tailored approach to “skin in game” rules, 95:724
– – SEC rule proposals, 94:152; unanimous vote on fixes for key weaknesses, 94:688; proposed new framework might include bank holding comapnies and financial holding companies, 95:452; proposed rule on issuer review and debate on need for minimum standard, 95:683
– – TALF “instrumental” in bringing back market, FRB Chicago report, 95:844

– Auction rate bonds and preferred securities

See AUCTION RATE SECURITIES

– Auctions, Treasury Dep't crisis borrowing programs, likely declines in demand, 94:269
– Broker-dealers, expansion of SIPA protections, Hill Watch, 95:428
– Brokers, FINRA proposal on expansion of information publicly available online, 94:364
– Build America Bonds, Grassley (R-Iowa) call for GAO cost-benefit analysis, 95:933; IRS clarification of draw-down deadline, 95:978; bank-qualified financing extension on bond counsel and borrower wish list, 95:979; Cross defense of program, 95:1069
– Citigroup

– – Misrepresentation and breach of fiduciary duty, FINRA arbitration panel ruling on compensatory and punitive damages, 95:635
– – Negligence charges, tentative approval of proposed settlement (D.D.C.), 95:526

– Collateralized debt obligations

– – Eastern Financial Fla. Credit Union collapse, failure of regulators in recognizing dangers, 94:923
– – SEC Structured and New Products Unit studies, 94:852

– Corporate deception, public in favor of more rights for investors, 94:160
– Credit default swaps

See CREDIT DEFAULT SWAPS (CDS)

– Debt instruments, N.Y. State Bar Ass'n group request for clarification of publicly traded, 94:661
– Distressed debt, duties and legal liability for indenture trustees, claims against JPMorgan Chase Bank dismissed (N.Y. Ct. App.), 94:662
– Dually registered proprietary traders, SEC proposal for temporary rule extension, 95:1020
– Enforcement, FINRA statistics for 2009, 95:64
– European Union

– – Market in Financial Instruments Directive (MiFID), high-frequency trading, dark capital pools, and commodity speculation as targets for oversight, 95:534
– – OTC equity settlement protocol, leading financial institution agreement, 95:641

– Examinations by OCIE, longer and tougher exams for some advisers and broker-dealers likely, di Florio remarks, 94:612
– Fiduciary duty standards of care

– – Different functions of broker-dealers and investment advisers, financial scholars' call for recognition, 95:465
– – Extension of fiduciary duty standard of care to all financial intermediaries, Aguilar remarks, 94:611
– – Harmonization for for investment advisers and broker-dealers, Congress's responsibilities, panel discussion, 94:708
– – Hill Watch, 94:712
– – SIFMA alternative to requirements for brokers providing investment advice, 95:405

– Financial advisors, level playing field provisions in RAFSA discussion draft, 94:107
– Firewalls between research and investment personnel, request to modify provision in 2003 analyst settlement declined (S.D.N.Y.), 94:565
– Fixed-rate commercial mortgage-backed securities, Citigroup report on delinquency rate, 94:923
– Flash crash, Senate Banking Comm. hearing on causes of May 6 stock market turmoil, 94:977; role of market makers part of ongoing SEC and CFTC review, 94:1091
– Fraud

See FRAUD

– Global financial crisis, lawsuit evolving towards more complex financial products, consultants say, 94:1199
– Guaranteed investment contracts and derivatives, proposed SEC civil charges against JP Morgan Chase, 94:959
– Insider trading, SEC access to wiretaps in some cases (2d Cir.), 95:581
– Litigation forecast, 2008 credit crisis and subprime crisis, financial institutions as plaintiffs and defendants, 95:941
– Maiden Lane assets

– – FRB holdings collectively worth more than when first added to books, 95:210
– – Material from FRB N.Y., steep decline in asset values, 94:653

– Morgan Keegan, FINRA arbitration panel ruling on compensatory and punitive damages, 95:635
– Mortgage-backed securities

– – Fannie Mae and Freddie Mac buyback plans for seriously delinquent loans, 94:315
– – FRB exit strategy for purchases, 94:205
– – Morgan Stanley and affiliates, alleged violations in sales to pension fund (S.D.N.Y.), 95:323
– – TALF purchases, smooth ending to FRB program, 94:644

– Negligent representation of delinquency data, Deutsche Bank fine to resolve FINRA claims, 95:169
– Parmalat collapse, dismissal of claims by SPEs against BoA (S.D.N.Y.), 94:374
– Point-of-sale disclosures, SEC review of financial products other than mutual funds, 94:324
– Private equity investments in banks through silo structures, FRB opposition to approach, 95:832
– Private Securities Litigation Reform Act, notice provision only applicable to federal claims (D. Conn.), 95:847
– Regulatory reform, SEC request for input from attorneys, 94:868; proxy access regime discussion, 95:8
– Repurchase agreement clearing system, closer oversight necessary, central bank remarks, 95:473
– Reverse repurchase counterparties, FRB N.Y. criteria and issues form, 95:520
– Small Business and Community Lending Initiative, initial Treasury Dep't acquisitions, 94:603
– Standard of care for broker-dealers and investment advisers, SEC use of 2008 Rand Study in regulatory review, 95:576; Walter remarks on study, 95:883
– Statistics, BIS report, fourth quarter 2009, 94:436
– Stock borrowing, Citigroup Global Markets FINRA fine for program facilitating investors' short selling, 94:701
– Taxation, contracts styled to look like options, IRS rejection of options tax treatment, 95:884; IRS advice memo analysis, BNA Insights, 95:1089
– Terrorism financing, SEC statement and guidance on obtaining beneficial ownership information for certain accounts, 94:522
– Treasury financing

– – Debt securities, dealers forecast annual budget deficit to fall in FY2011, 95:837
– – Inflation-protected securities (TIPS), extra sales added to auction roster for 2011, 95:838
– – International Capital data, Nov. 2009 report, 94:151
– – Notes, call for Large Position Reports, 95:1070

– Trust preferred securities (TRUPS), additional Treasury Dep't sales of equity in Citigroup, 95:563
– Underperforming residential mortgages, BoA and Citigroup disclosure of potential lawsuit losses, 95:846
– United Kingdom

– – JP Morgan Securities fine for breaching rules for protecting clients' money, 94:1141
– – Royal Bank of Scotland penalties following investigation into anticompetitive conduct, 94:662

– Unregistered affiliates, clarification of OCIE authority, Aguilar remarks, 94:611
– Variable annuity accounts, FINRA examination of leveraged exchange-traded funds in some portfolios, 94:912
– Wachovia Global Securities Lending, St. Petersburg claims for breach of contract, breach of fiduciary duty, and negligence may continue (M.D. Fla.), 95:230

SECURITIES AND EXCHANGE COMMISSION (SEC)

– Creation and staffing of new offices required by Dodd-Frank Act, deferral during budget uncertainty, 95:1022
– Enforcement policy, Outlook 2010, Special Report, 94:184
– IG post as presidential appointment, Kotz remarks, 94:979
– Regulatory policy, Outlook 2010, Special Report, 94:188

SECURITIZATION

– Accounting, bank arguments for broader FASB deferral of consolidation rules for asset managers, 94:132; FASB deferral extension for certain asset management activities, 94:220
– Asset-backed securities, SEC extends no-action stance allowing issuers to omit ratings data, 95:972
– Commercial mortgage-backed securities

– – Citigroup Global Markets analysis of new offerings, 95:626
– – Delinquency rate for loans, TreppWire report, May 2010, 94:1185; Oct. 2010, 95:845
– – Demand outstrips supply in current market, Analysis and Perspective, 95:81
– – Renewed activity possible based on 3 new transations, 95:358

– Commercial real estate, economic outlook, conference speakers' remakrs, 95:691
– Covered bonds

– – Garrett (R-NJ) measure on alternatives to commercial mortgage-backed securites, 94:566
– – Primer, BNA Insights, 94:1108

– Financial system reform, federal regulator concerns about unintended consequences, 94:1174
– Mortgage-backed securities purchases, smooth ending to TALF program, 94:644
– Mortgage servicing, Countrywide Financial, potential investor calls for buybacks, 95:722
– Priority claims

– – FDIC not allowed precedence over claims of holders of notes issued by failed NextBank N.A. trust under N.Y. law (2d Cir.), 94:1142
– – Loan collateral lost by listing debtor's trade name as part of debtor's organization name on financing statement (8th Cir.), 94:984

– Registration relief for certificates in SEC pilot program, 95:104
– Revival of markets, protection against future shocks, Bair remarks, 95:874
– Risk retention, U.S. regulators at work on rules while EU already setting rigid standards, 95:773
– Safe harbor protections

– – Failed banks, FDIC extension, 94:506
– – Securities originated by failed banks, FDIC notices of proposed rulemaking, 94:958; financial services industry groups' push for coordination with financial reform legislation, 95:52

– Secondary market, improvements pointing to initial structured finance recovery, 94:313
– Subprime mortgages

– – Market as factor in GSE collapse, Greenspan testimony, 94:689
– – Morgan Stanley settling allegations of predatory loans (Mass. Super. Ct.), 94:1304

SLOVENIA

– Extension of bank support scheme, European Comm'n approval, 95:29

SMALL BUSINESSES

– Accounting, financial instruments, small private banks and other private enterprises, tentative decision on delaying effective date of FASB rules, 94:400
– Agriculture, USDA Rural Development's Business and Industry Guaranteed Loan Program, award announcements, 95:265
– Audits, underwriting and other problems with some §504 lending by Premier Certified Lenders, SBA IG remarks, 94:798
– Availability of credit

– – FRB efforts, Bernanke remarks, 94:1126
– – House measure

See LEGISLATION, FEDERAL, HR 5297

– – Treasury certification measure

See LEGISLATION, FEDERAL, HR 5551

– Borrowing, FRB conference agenda, 95:102
– CIT Group, naming of final 3 independent board members, 94:111; chairman and CEO named, 94:326
– Commercial real estate loans, Pres. Obama proposal allowing refinancing through SBA, 94:317
– Communities at Work Fund, Citigroup partnership with community investment groups, 94:923
– Credit decisions by lenders, federal and state regulator statements, 94:260
– Financial regulatory system overhaul, small bank supervision, FRB authority necessary, Bernanke remarks, 94:545
– Gulf of Mexico oil spill, SBA economic injury disaster loans, 94:916
– Lack of availability of capital and bank loans

– – NSBA report, 94:151
– – Senate Comm. on Small Bus. and Entrepreneurship roundtable, 94:1182

– Layoffs from credit problems hurt recovery, Krueger testimony, 94:917
– Lending fund, Snowe (R-Maine) remarks on strict oversight needs, 95:578
– Liquidity, FRB questionnaire on lending improvements, 95:299
– Local programs, Treasury Dep't funding announcement, 95:630
– Regulatory reform, Financial Servs. Roundtable agenda for expanding loan programs, 94:424
– Securities, initial Treasury Dep't acquisitions under Small Business and Community Lending Initiative, 94:603
– Stimulus, Senate actions

See LEGISLATION, FEDERAL, S 2862, S 2869

– TARP funds

– – Congressional Oversight Panel field hearings, differing opinions on solutions to crisis, 94:855
– – Pres. Obama pledge of $30B to community banks for loans, 94:222
– – Shortage of loans, House joint committee hearing on alternative approaches, 94:416
– – Small banks, Congressional Oversight Panel report on impact of repayment obligations, 95:98
– – Treasury Dep't failures in lending programs, COP report, 94:961

– Taxation

See LEGISLATION, FEDERAL, HR 5486

– Turnaround in lending by end of 2010, Duke remarks, 94:651
– Underserved communities, SBA programs to increase lending to firms and entrepreneurs, 95:1118
– Underwater collateral impact on borrowing and rolling over existing loans, 94:463
– Weak hiring links to tight credit, differing opinions from analysts, 94:523

SMALL DOLLAR LOANS

– Credit unions, NCUA rule approval, 95:459
– Research, 2-year pilot program proves safety of alternatives to high-cost emergency credit products, 94:1290

SOUTH CAROLINA

– Failed banks

– – Beach First Natl. Bank of Myrtle Beach, 94:702
– – First Natl. Bank of South, Spartanburg, 95:99
– – Williamsburg First Natl. Bank in Kingstree, 95:152
– – Woodlands Bank in Bluffton, 95:99

SOUTH KOREA

– International banking and finance, support for global levy on bank's non-core, non-depository liabilities, 94:886

SPAIN

– Bank recapitalization plan, European Comm'n approval, 94:239
– Credit cards, systematic transaction reporting requirements, 94:117
– Money laundering, harmonization with EU standards, 94:890
– Restructuring of savings banks, acceleration of reform efforts, 94:940; joint effort toward financial reform between government and opposition party, 94:1147; reinforcement of regional savings banks, 95:118
– Stress test results, publication likely, 94:1264
– Terrorism, harmonization with EU terror financing standards, 94:890

STATE AND LOCAL GOVERNMENT

– Consumer credit, N.Y.C. program plans, 94:155
– Foreclosure crisis, state legislation statistics, 94:140

STATE AND LOCAL TAXES

– Apportionment rules, Mich. measure for restructured financial institutions, 94:155
– Nonbank subsidiaries of banks, Va. income tax demands on 2 banks, 94:478

STUDENT LOANS

– Bankruptcy, Chapter 13 plans discharging debt in absence of undue hardship determination (U.S., judg aff), 94:621
– Default rates, Education Dep't report for FY2008, 95:459
– Delinquency rates, fourth quarter 2009, 94:927
– End of subsidies for loan originators

See LEGISLATION, FEDERAL, HR 3221, HR 4872

– Guaranty agencies, removal of Cal. commission designation as federal agent, 95:226
– Preemption, Cal. class action claims against Sallie Mae interest rates, late fees, and payment schedules (9th Cir.), 94:236

SUBCHAPTER S CORPORATIONS

– ARRA, temporary reduction in 10-year recognition period for built-in gains tax relief, impact of technical corrections measure, 94:696
– Back-to-back loans, IRS guidance release soon, 94:975
– QSub Bank, shareholders deductions for full amount of interest expenses relating to qualified tax-exempt obligations (7th Cir.), 94:575
– Taxation, interest expense disallowance rule not applicable to bank (7th Cir.), 95:1126

SUBPRIME MORTGAGES

– Consumer protection, N.Y. rules with duty of fair dealing, 95:319
– Credit rating agencies, knowing use of outdated models in assessments, Senate Permanent Subcomm. on Investigations findings, 94:791
– Foreclosure, national rate, FRB N.Y. data, 94:979
– Fraud

– – Citigroup, market exposure, SEC charges of material misrepresentations (D.D.C.), 95:215; reconsideration of preliminary settlement agreement, 95:327; final court approval of settlement, 95:699; Investment Advisers Act relief, 95:797
– – Financial Crisis Inquiry Comm'n investigation, 94:272
– – Goldman Sachs and senior executive, alleged misstatements and omissions in connection with structuring and sale of subprime residential mortgage-backed derivatives (S.D.N.Y.), 94:735; correction to page 94:735, 94:795; potential impact of enforcement action, 94:803; no links between enforcement action and reform legislation, 95:682

– Nuisance suit by Cleveland against more than 20 financial firms dismissed (6th Cir.), 95:229
– Securitization

– – Market as factor in GSE collapse, Greenspan testimony, 94:689
– – Morgan Stanley settling allegations of predatory loans (Mass. Super. Ct.), 94:1304

– Underwater mortgages, links to defaults under study by GAO, 94:1249

SUPREME COURT, U.S.

– Arbitration, delegation provision challenge resolved in federal district court (rvs), 94:1303
– Argentine assets, immunity from claims by hedge funds and other investors (rev den), 94:483
– Bankruptcy

– – Ownership cost deduction for unencumbered vehicles owned by above-median income debtor (rev grant), 94:819; (oral arg), 95:636
– – Projected disposable income, forward-looking approach acceptable (judg aff), 94:1194
– – Student loans, Chapter 13 plans discharging debt in absence of undue hardship determination (judg aff), 94:621

– Bounced checks, withdrawal of invalid funds (rev den), 95:581
– Class arbitration

– – Federal Arbitration Act does not support imposition arbitration when agreement silent (rvs and rem), 94:881
– – Merchant fees as illegal tie-ins imposed in Amex card acceptance agreement (judg vac), 94:884
– – Protection of agreements from state laws prohibiting use of contracts requiring waiver of class action rights (rev grant), 95:746
– – Securities fraud claims by non-U.S. investors, extraterritorial reach of federal laws (aff), 95:24

– Consumer financial privacy, borrower claims (rev den), 95:581
– Credit cards, change-in-terms notice requirements under TILA (rev grant), 94:1254; FRB amicus brief (oral arg), 95:1072
– Fair Debt Collection Practices Act, untimely homeowner/borrower claims (rev den), 95:581
– Judicial taking theory in Fla. beach erosion dispute rejected (judg aff), 94:1256
– Kagan's expertise in administrative law, possible role in wake of financial system reform, 94:986
– Pensions, fractional test in cash balance plan, alleged ERISA violation by Citigroup (U.S., rvs), 95:26
– Regulation Z, Solicitor General input on creditor requirements for default-related credit card interest rate increases (brief requested), 94:236
– RESPA anti-kickback provisions, lender payments to mortgage brokers (rev den), 95:581
– Separation of powers doctrine, Sarbanes-Oxley Act provision on “for cause” removal of PCAOB members unconstitutional (aff in part, rvs in part), 95:22
– TILA disclosure provisions, timeliness of claims (rev den), 95:581

SURVEYS

– Senior Loan Officer Opinion Survey

See CREDIT MARKETS

SWEDEN

– HQ Bank trading license, challenge of revocation order from federal regulators, 95:423
– Payment cards, prohibition of card fees and amendment of negligence liabilities, 95:280

SWITZERLAND

– Bank secrecy

– – French return of stolen data to HSBC Private Bank (Suisse), 94:31; tentative informal understanding, 94:243; identification of account holders, 94:774
– – Voters reject effort to place referendum of revisions on ballot, 95:706

– Capital adequacy standards, adoption of new international and EU norms, 95:119
– Discrimination against U.S. clients by banks following tax crackdown, senior regulator remarks, 94:630
– Executive compensation, government support for measures targeting big banks, 94:887
– Stress tests, largest banks pass, 95:174
– Systemic risk, government preparation of implementing legislation for “too big too fail” provisions, 95:706
– Tax evasion crackdown

– – Declaration of bank assets, government ready for negotiations with interested countries, 94:437
– – Double tax agreements, Parliament approves revised pacts with 10 countries, 94:1209
– – Insurance, financial regulator warning on use of “wrappers” as tax shelters, 94:711
– – Loss of funds from important EU clients, 94:386

– Tax treaties

– – Expansion of cross-border assistance in tax investigations, implementing regulations, 95:424
– – Germany, continuation of negotiations despite dispute over stolen bank data, 94:291

– UBS

– – Auction rate securities sales practices, UBS finalizes settlement with SEC, 94:480; FINRA arbitration panel ruling, 95:268
– – Deadline for handing over names marks new disclosure landscape, Analysis and Perspective, 95:375
– – Developing aftermath of tax evasion case, BNA Insights, 95:647
– – FBAR penalties, 7 clients charged with hiding more than $100M (S.D.N.Y.), 94:764
– – Financial adviser charged with tax fraud conspiracy for alleged scheme to persuade U.S. client from disclosing account (S.D. Fla.), 95:1128
– – Financial market agency authority exceeded in ordering transfer of client data to U.S. tax authorities, 94:75; court ruling, 94:116; exclusion of some data from handover to IRS, 94:157; data on 250 secret accounts in handover, 94:234; urgent talks to continue, 94:244; U.S. unwilling to renegotiate data disclosure deal, 94:307; further rulings declined, 94:486; UBS lobbying for approval of tax accord with U.S., 94:531; Leuthard calls ratification of agreement important, 94:631; new protocol to treaty announced, 94:667; push for parliamentary approval of deal, 94:767; appeal of court ruling rejected, 94:818; parliamentary commission recommendation, 94:823; increased chances for parliamentary approval of agreement, 94:1105; upper legislative house approval of deal, 94:1145; second upper legislative house approval of deal, 94:1206; final approval to agreement without referendum, 94:1264; court order for reconsideration of clients' appeal to information exchange, 95:170; deadline for processing accounts met but handover not complete, 95:344
– – Recouping $37M from bank for cost of implementation of U.S. tax deal, 94:889
– – Shareholders' refusal to shield former board of directors and management from possible legal action, 94:764; denial of discharge to members of 2007 board, 94:769
– – Tax fraud allegations, IRS withdraws “John Doe” summons, 95:910
– – Whistleblowing banker's prison term postponement and sentence reduction request (S.D. Fla.), 94:25; allegedly incomplete and misleading statements by DOJ attorneys during sentencing hearing, 94:75

SYSTEMIC RISK

– Accounting, interest group request to include standards in scope of council, 94:206
– Advisory body, Financial Roundtable suggestion, 95:920
– Appropriate risk-taking, American Bar Ass'n Tax Section discussion, 94:145
– Bank supervision, FSB call for improvements in oversight of “too big to fail” banks, 95:852; FSB sets schedule for implementation of SIFI rules, 95:868
– Basel III negotiations, issue of “too big to fail” institutions, 95:545
– Deposit insurance, impact of risk exception in FDI Act on market discipline, GAO report, 94:750
– Designation of systemically important financial institutions, Financial Stability Oversight Council, request for comment on implementation plans, 95:553; challenges not necessarily prudent, attorneys' remarks, 95:669
– EU, permanent crisis resolution mechanism with financial market liability for euro zone, 95:802; IMF warning of insufficient regulation, 95:1088
– Insurance, industry concerns about impact of Senate financial services regulatory reform proposal, 94:554; industry group warnings about potential market disruptions, 95:1086
– Legal entity identifiers, OFR adoption of universal standard for labeling parties to financial contracts, 95:1020
– Monetary policy, possible oversight council recommendations, FRB N.Y. official remarks, 95:251
– Oversight of financial markets

– – Creation of federal regulator, Paredes remarks, 94:652
– – FSB remarks on vulnerability of global financial system, 95:531
– – Level playing field provisions for financial advisors in RAFSA discussion draft, 94:107

– Payment systems, FSOC request for preliminary feedback on gauging risk posed by managers or operators, 95:963
– Regulatory reform, new world of systemically risky financial firms and impacts on creditors, BNA Insights, 95:540
– Resolution infrastructure and incentives, FRB Boston recommendations, 94:963
– Stress tests, Congressional Oversight Panel recommendations for evaluation of potential fallout from mortgage errors, 95:874
– Switzerland, final panel recommendations on limiting risk from “too big to fail” banks, 95:643
– TARP, Citigroup bailout, Congressional Oversight Panel concerns, 94:467
– Tri-party repo markets, federal banking officials and FRB N.Y. recommended changes, 94:957; comments from financial institutions, 95:294
– Volcker rule prohibiting risky trading at federally insured banks

– – Enforcement policy, FRB proposed compliance period, request for public comment, 95:910
– – Financial Stability Oversight Council, request for comment on implementation plans, 95:553; Merkley (D-Or) and Levin (D-Mich) urge tough stance, 95:829
– – Opposition to rule, Cohen remarks, 94:464
– – Proprietary trading

– – – Drawing line with market making regulatory challenge, 95:961
– – – Limits, Hill Watch, 94:712

– – Senate actions, rule included in financial system reform measure, 94:499; measure reviving rule again, 94:504; further action, see LEGISLATION, FEDERAL, HR 4173
– – SIFMA warnings of legal uncertainty in fund restrictions, 95:877
– – Venture capital funds, FRB examination of role of bank investments, 95:832