Ameriprise 2012 Annual Report Download - page 39

Property Casualty and $730,404 for Ameriprise Insurance Company. As of December 31, 2012, IDS Property Casualty had
$462 million of total adjusted capital, or 704% of the company action level RBC, and Ameriprise Insurance Company had
$43 million of total adjusted capital, or 5847% of the company action level RBC.
Ameriprise Financial, as a direct and indirect owner of its insurance subsidiaries, is subject to the insurance holding
companies laws of the states where its insurance subsidiaries are domiciled. These laws generally require insurance
holding companies to register with the insurance department of the insurance company’s state of domicile and to provide
certain financial and other information about the operations of the companies within the holding company structure. In
addition, transactions between an insurance company and other companies within the same holding company structure
must be on terms that are considered to be fair and reasonable.
Federal Banking Regulation
In 2012, Ameriprise Bank requested regulatory approval to convert from a federal savings bank to a limited powers
national trust bank. We completed this conversion, as well as the renaming of the entity as Ameriprise National Trust Bank,
January 2013. As a limited powers national association, Ameriprise National Trust Bank remains subject to supervision
under various laws and regulations enforced by the OCC, including those related to capital adequacy, liquidity and conflicts
of interest, and to a limited extent, by the FDIC.
Prior to the conversion, Ameriprise Financial, as the sole owner of Ameriprise Bank, was subject to consolidated regulation,
supervision and examination by the Board of Governors for the Federal Reserve System (‘‘FRB’’) as a savings and loan
holding company. In addition, Ameriprise Financial had previously elected to be classified as a financial holding company
subject to regulation under the Bank Holding Company Act of 1956 (as amended), which election imposed certain
restrictions on the activities of Ameriprise Financial and required both Ameriprise Financial and Ameriprise Bank to remain
well capitalized, well managed and to have a sufficient standing under the Community Reinvestment Act. Following the
conversion of Ameriprise Bank, Ameriprise Financial deregistered as a savings and loan holding company and is no longer
subject to consolidated regulation or supervision by the FRB as such, nor is it subject to the additional FRB requirements
applicable to financial holding companies.
Parent Company Regulation
Ameriprise Financial is a publicly traded company that is subject to SEC and New York Stock Exchange (‘‘NYSE’’) rules and
regulations regarding public disclosure, financial reporting, internal controls and corporate governance. The adoption of the
Sarbanes-Oxley Act of 2002 significantly enhanced these rules and regulations and may continue to evolve.
We have operations in a number of geographical regions outside of the U.S. through Threadneedle and certain of our other
subsidiaries. We monitor developments in European Union (‘‘EU’’) legislation, as well as in the other markets in which we
operate, to ensure that we comply with all applicable legal requirements, including EU directives applicable to financial
institutions as implemented in the various member states. Because of the mix of business activities we conduct, we
continually assess the impact of, and ensure compliance with, the EU Financial Conglomerates Directive, which
contemplates that certain financial conglomerates involved in banking, insurance and investment activities among other
things, implement measures to prevent excessive leverage and multiple leveraging of capital and maintain internal control
processes to address risk concentrations as well as risks arising from significant intragroup transactions.
Privacy
Many aspects of our business are subject to comprehensive legal requirements by a multitude of different functional
regulators concerning the use and protection of personal information, particularly that of clients. This includes rules
adopted pursuant to the Gramm-Leach-Bliley Act, the Fair and Accurate Credit Transactions Act, an ever increasing number
of state laws, and EU data protection legislation as domestically implemented in the respective EU member states. We
have also implemented policies and procedures in response to such requirements in the UK. We continue our efforts to
safeguard the data entrusted to us in accordance with applicable law and our internal data protection policies, including
taking steps to reduce the potential for identity theft or other improper use or disclosure of personal information, while
seeking to collect and use data to properly achieve our business objectives and to best serve our clients.
USA Patriot Act
The Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act,
commonly referred to as the USA Patriot Act, was enacted in October 2001 in the wake of the September 11th terrorist
attacks. The USA Patriot Act broadened existing anti-money laundering legislation and the extraterritorial jurisdiction of the
United States substantially. In response, we enhanced our existing anti-money laundering programs and developed new
procedures and programs. For example, we implemented a customer identification program applicable to many of our
businesses and enhanced our ‘‘know your customer’’ ‘‘and ‘‘due diligence’’ programs. In addition, we will continue to
comply with anti-money laundering legislation in the UK derived from applicable EU directives and international initiatives
adopted in other jurisdictions in which we conduct business.
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