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The Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act") contains several provisions that will tighten the restrictions that govern transactions between banks and their affiliates – Sections 23A and 23B of the Federal Reserve Act – beginning in July 2012. These new provisions will (i) significantly increase the cost and burden of certain types of transactions between a bank and its nonbank affiliates, in particular, derivatives, securities lending/borrowing, and repo transactions; (ii) expand the scope of "affiliates" subject to Sections 23A and 23B; and (iii) increase the collateral burdens applicable to extensions of credit. As a result, banks should review, and may be required to modify, existing business arrangements with affiliates (as newly redefined) to comply with the new requirements