Asset and Wealth Management Activities

Banking organization asset and wealth management (AWM) activities include traditional trust services such as investment management, investment advisory, personal trust, corporate trust, transfer agent services, and certain employee benefit account services, as well as securities custody, securities lending, securities clearing and settlement, and functionally regulated securities broker-dealer and registered investment advisor activities. Serving as trustee and paying agent for bond issues including structured debt and asset-backed issues also is considered an AWM activity. The administration of AWM services is a significant line of business for most large, complex banking organizations as well as many smaller banking organizations, and services often are delivered in an integrated manner.

Policy Letters

Asset and Wealth Management Activities

Compliance Risk Management Programs and Oversight at Large Banking Organizations with Complex Compliance Profiles

Interagency Statement on Sound Practices Concerning Elevated Risk Complex Structured Finance Activities

Reports of Examinations of Government Securities Activities

Frequently Asked Questions Relating to Customer Identification Program Rules

Interagency Policy on Banks/Thrifts Providing Financial Support to Funds Advised by the Banking Organization

Examination of Fiduciary Activities

Supervisory Guidance Regarding the Investment of Fiduciary Assets in Mutual Funds and Potential Conflicts of Interest

Uniform Interagency Trust Rating System

Conversion of Common Trust Funds to Mutual Funds

Risk-Focused Fiduciary Examinations

Interpretation of Interagency Statement on Retail Sales of Nondeposit Investment Products

Investment Adviser Activities

Examination Procedures for Retail Sales of Nondeposit Investment Products

Coordination of Specialty Examinations with Full Scope Safety and Soundness Examinations of State Member Banks

Interagency Statement on Retail Sales of Nondeposit Investment Products

Supplemental Guidance for the Inspection of Nonbank Subsidiaries of Bank Holding Companies

Elements of a Sound Conflict of Interest Program

Guidelines for the Inspection of Investment Adviser Subsidiaries of Bank Holding Companies

Bank Holding Company Funding from Sweep Accounts

Sale of Uninsured Debt Obligations and Securities Issued by Bank Holding Companies, Nonbank Affiliates, or State Member Banks on Retail Banking Premises

Examination of State Branches and Agencies of Foreign Banks for Compliance with Regulations Related to Government Securities Activities

Additional Resources

Manual References

  • Bank Holding Company Supervision Manual
    • Section 2010.0, "Supervision of Subsidiaries"
    • Section 2010.12, "Fees Involving Investments of Fiduciary Assets in Mutual Funds and Potential Conflicts of Interest"
    • Section 2080.5, "Section 2080.5 Funding (Pension Funding and Employee Stock Option Plans)"
    • Section 2140.0, "Securities Lending"
    • Section 2178.0, "Support of Bank-Affiliated Investment Funds"
    • Section 2187.0, "Violations of Federal Reserve Margin Regulations Resulting from 'Free-Riding' Schemes"
    • Section 3120.0, "Section 4(c)(8) of the BHC Act (Trust Services)"
    • Section 3130.0, "Section 4(c)(8) of the BHC Act (General Financial and Investment Advisory Activities)"
    • Section 3130.1, "Section 4(c)(8) of the BHC Act (Investment or Financial Advisers)"
    • Section 3230.0, "Section 4(c)(8) – Agency Transaction Services for Customer Investments (Securities Brokerage)"
    • Section 3600.21, "Permissible Activities by Board Order (Underwriting and Dealing)"
    • Section 3900.0, "Financial Holding Companies (Section 4(k) of the BHC Act)"
    • Section 3907.0, "Merchant Banking (Section 4(k) of the BHC Act)"
  • Commercial Bank Examination Manual
    • Section 5200.1, "Fiduciary Activities"
    • Section 5210, "Private-Banking Activities"
    • Section 5220.1, "Employee Benefit Trusts"
    • Section 6074.1, "Regulation W: Investment-Funds Support"
  • Other Trust-Related Manuals
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Last Update: October 03, 2023