id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
cblr-7161	Humble, Mackenzie	The Treacherous Landscape For Foreign G-Sibs: The IHC Framework And Financial Stability 	2020	60	.pdf	application/pdf	20663	928	48	Intra- company derivatives transactions are extremely important li- quidity risk management tools for financial institutions, and have historically afforded large financial institutions, partic- ularly those with complex legal entity structures, the ability to hedge risks and absorb liquidity shocks across their organ- izations.150 Now that the exemption has been eliminated and intracompany derivatives transactions are limited by the ten percent and twenty percent limits of Regulation W, some com- mentators have noted that banks’ ability to manage their risks is “totally change[d].”151 Further, others have shared concerns that the elimination of the exception undermines 146 See Omarova, supra note 75, at 1727–28; Letter from Sen. Bob. Recall that any retained earnings that are not so remit- ted will be counted toward the ten percent and twenty percent limits of Regulation W. Additionally, any remittance the IHC attempts to make back to its U.S. financial subsidiaries (or any of its subsidiaries globally) will be subject to the ten per- cent single affiliate and twenty percent aggregate limits of Regulation W. As noted earlier, this outcome serves not only to deprive liquid capital from global affiliates of FBOs, but it also puts U.S. financial subsidiaries at risk.	cache/cblr-7161.pdf	txt/cblr-7161.txt