Yes, the holding company that owns your bank is considered your affiliate under Regulation P. The rule defines “affiliate” as “any company that controls, is controlled by, or is under common control with another company.”

Under the Bank Holding Company Act, a holding company controls a bank if it directly or indirectly or owns or controls at least 25% of the bank’s voting securities. In this case, your holding company owns 100% of your bank, which satisfies the element of control.

For resources related to our guidance, please see:

• Regulation P, 12 CFR 1016.3 (“Affiliate means any company that controls, is controlled by, or is under common control with another company.”)

• Bank Holding Company Act, 12 USC 1841 (“Any company has control over a bank or over any company if— (A) the company directly or indirectly or acting through one or more other persons owns, controls, or has power to vote 25 per centum or more of any class of voting securities of the bank or company . . . “)