BB&T 2014 Annual Report Download - page 17

Table of Contents
Foreign Account Tax Compliance Act and Conforming Regulations
In May 2014, the IRS issued Notice 2014-33 (the “Notice”) regarding FATCA and its related withholding provisions. The Notice announces that calendar
years 2014 and 2015 will be regarded as a transition period for purposes of IRS enforcement and administration with respect to the implementation of FATCA
by withholding agents, foreign financial institutions and other entities with IRC chapter 4 responsibilities. The Notice also announces the IRS’s intention to
further amend the regulations under Sections 1441, 1442, 1471, and 1472 of the IRC. Prior to the IRS issuing these amendments, taxpayers may rely on the
provisions of the Notice regarding the proposed amendments to the regulations. The transition period and other guidance described in the Notice are
intended to facilitate an orderly transition for withholding agent and foreign financial institution compliance with FATCA’s requirements and respond to
comments regarding certain aspects of the regulations under chapters 3 and 4 of the IRC. BB&T expects to be in compliance with FATCA and its related
provisions by the applicable effective dates.
Volcker Rule
The Volcker Rule implements section 619 of the Dodd-Frank Act and prohibits IDIs and affiliated companies ("banking entities") from engaging in short-
term proprietary trading of certain securities, derivatives, and commodity futures, and options on these instruments, for their own account. The final rules also
impose limits on banking entities' investments in, and other relationships with, hedge funds or private equity funds. Like the Dodd-Frank Act, the rules
provide exemptions for certain activities, including market making, underwriting, hedging, trading in government obligations, insurance company activities,
and organizing and offering hedge funds or private equity funds. The rules also clarify that certain activities are not prohibited, including acting as agent,
broker, or custodian.
The compliance requirements under the rules vary based on the size of the banking entity and the scope of activities conducted. Banking entities with
significant trading operations will be required to establish a detailed compliance program, and their Chief Executive Officers will be required to attest that
the program is reasonably designed to achieve compliance with the final rules. Independent testing and analysis of an institution's compliance program also
will be required. The final rules reduce the burden on smaller, less-complex institutions by limiting their compliance and reporting requirements.
Additionally, a banking entity that does not engage in covered trading activities will not need to establish a compliance program.
Banking entities must conform proprietary trading activities to the final rule by July 21, 2015. The FRB has extended the compliance deadline to July 21,
2016 for purposes of conforming investments in and relationships with covered funds and foreign funds that were in place prior to December 31, 2013. The
FRB also announced its intention to grant banking entities an additional one-year extension of the conformance period for legacy funds to July 21, 2017.
These requirements are not expected to have a material impact on BB&T’s consolidated financial position, results of operations or cash flows.
Deposit Insurance Assessments
Branch Bank’s deposits are insured by the DIF of the FDIC up to the limits set forth under applicable law. The FDIC imposes a risk-based deposit premium
assessment system that determines assessment rates for an IDI based on an assessment rate calculator, which is based on a number of elements to measure the
risk each IDI poses to the DIF. The assessment rate is applied to total average assets less tangible equity, as defined under the Dodd-Frank Act. The assessment
rate schedule can change from time to time at the discretion of the FDIC, subject to certain limits. Under the current system, premiums are assessed quarterly.
Consumer Protection Laws and Regulations
In connection with its lending and leasing activities, Branch Bank is subject to a number of federal and state laws designed to protect borrowers and promote
lending to various sectors of the economy and population. These laws include the Equal Credit Opportunity Act, the Fair Credit Reporting Act, the Truth in
Lending Act, the Home Mortgage Disclosure Act, the Real Estate Settlement Procedures Act, and their respective state law counterparts.
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Source: BB&T CORP, 10-K, February 25, 2015 Powered by Morningstar® Document Research℠
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