Posts by Viktar Ramanovich

TAX DEVELOPMENTS Treasury Issues Final Regulations Regarding Transfer for Value Rules Involving 1035 Exchanges On July 9 the IRS and Treasury issued final regulations providing guidance on the application of the transfer for valuable consideration rules and associated information reporting requirements for reportable policy sales of interests in life insurance contracts to exchanges of life…

REGULATORY DEVELOPMENTS Banking Regulators Remove References to Reputation Risk from Interagency Guidance On June 2 the banking regulators reissued 15 interagency guidance documents to remove references to reputation risk (OCC Bulletin 2026-23) (FDIC FIL-27-2026). The Interagency Statement on the Purchase and Risk Management of Life Insurance (commonly cited as OCC 2004-56) was included in the…

LEGISLATIVE DEVELOPMENTS Louisiana Proposed Legislation for BOLI 1035 Exchange A bill has been introduced in the Louisiana state senate (SB 509) that is directed toward BOLI exchanges – particularly exchanges of policies covering former employees. While we support the bill’s aim of clarifying that exchanges of policies covering former employees are permissible, as drafted, the…

REGULATORY DEVELOPMENTS Basel III Endgame – Regulators Release Proposed Regulatory Capital Rules As identified in our March 20 Ad Hoc LRA Update, the FDIC, Federal Reserve Board, and the OCC jointly announced the release of three separate regulatory capital rule proposals concerning the following: The proposals are open for comment until June 18. We have…

REGULATORY DEVELOPMENTS Basel III Endgame – Regulators Release Proposed Regulatory Capital Rules As has been well reported, federal banking regulators have long been considering a re-proposal of the previously released regulatory capital rules known as Basel III Endgame. On March 19 the FDIC, Federal Reserve Board, and the OCC jointly announced the release of three…

REGULATORY DEVELOPMENTS Basel III Endgame – Update Federal regulators continue to indicate that work is being done to revisit the previously proposed capital rules known as Basel III Endgame. FRB Vice Chair for Supervision Michelle Bowman recently gave remarks at an Exchequer Club event discussing the timeline for re-proposed capital rules. Bowman stated that “I’ve…