Anti-tying and Operational Risk Issues
March 24, 2006
On March 24, 2006, Bob Tortoriello authored an Alert entitled "Anti-tying Guidance and Operational Risk Issues". This ten-page memo is an update, current as of March 15, that complements, "Securities Activities of Banks in the GLB Era: Anti-tying and Operational Risk Issues" (current as of January 15). Both documents were prepared in connection with the SIA Compliance and Legal Division Annual Seminar held on March 22, 2006. The matters discussed in the Alerts -- tying questions, participation in complex structured finance transactions, operational risk issues and SEC supervisory developments -- have general applicability for financial institutions with U.S. banking and securities operations.