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In July 1997, the Federal Reserve Bank of New York (FRBNY) issued a paper on ‘Guidance on Sound Risk Management Practices Governing Private Banking Activities’ (the ‘Guidelines’). The paper is the culmination of the work of FRBNY bank examiners who recently concluded a year long study of 40 financial institutions in New York City with private banking departments. Private banking refers to the provision of financial services to high net worth individuals. FRBNY examiners evaluated the private banking policies and procedures of commercial banks, Edge Act corporations, trust companies and the US branches of foreign banks in an attempt to gauge the level of risk management at these institutions. The examiners found ‘varying degrees of sophistication and depth in private banking activities’.

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