Importantly, the interpretation proposes guidelines that could be followed when a bank seeks to engage in traditional “relationship banking,” that is, serving customers based on the profitability of the overall customer relationship, including the establishment of some regulatory “safe harbors.” The guidance would communicate our expectations as to the types of policies, procedures, internal controls, and training programs that should help banks comply with the anti-tying restrictions.
On the other hand, Japan’s economy could decline if developments in fiscal conditions in Greece and other economies further intensify strains in international financial markets or exert downward pressure on the global economy. Also, the consequences of balance-sheet adjustments in the United States and Europe continue to demand vigilance.