Regulatory Aspects of Devloping Nation Debt-Equity Swaps

This article discusses and analyzes three distinct legal doctrines available to the Office of the Comptroller of the Currency (the “OCC” or the “Office”) to issue policy statements and interpretive letters enabling banks to participate in transactions designed to restructure developing-country debt. Additionally, this article comments on Regulation K, promulgated by the Federal Reserve Board (the “Board”), which the Board twice amended in recent months to grant U.S. banks more investment flexibility in foreign operations.