Q: § __.12(a) – 1: Does the definition of “affiliate” include subsidiaries of an institution?
A: Yes, “affiliate” includes any company that controls, is controlled by, or is under common control with another company. An institution’s subsidiary is controlled by the institution and is, therefore, an affiliate.
This Interagency Q&A, and others, was released in July 2016.
The 2016 Q&As consolidates and supersedes all previously published “Interagency Questions and Answers Regarding Community Reinvestment,” and were noted as being effective immediately. They may be found here: http://www.ffiec.gov/cra/qnadoc.htm