Joseph Arkins


The Note argues that the Fed's approach in applying the BHCA to foreign government instrumentalities incorrectly characterizes them as "companies" under the Act. It further argues that the Fed's approach to regulating foreign government owned subsidiaries in the U.S. insufficiently accomodaets the financial interrelationship between these governments U.S. banking affiliates and their non-banking activities outside the U.S. The Note argues that the Fed has incorrectly characterized foreign banking instrumentalities as "companies", and therefore would excessively restrict their financial interrelationships in the event these instrumentalities acquire a U.S. subsidiary.