Reply To: Small Entity


I agree with cmitchell. They’re trying to assist banks without a large compliance staff. There’s no real limit on size of bank to which they apply.

The intros of the SECGs state:

Our goal with this guide is to provide a comprehensive rule summary in a plain language and FAQ format, which makes the content more accessible and consumable for a broad array of industry constituents, especially smaller businesses with limited legal and compliance staff.