Ameriprise 2013 Annual Report Download - page 40

and capital. New York has adopted the holding company act revisions and a draft ORSA regulation. Accordingly,
RiverSource Life of New York will be required to file its first enterprise risk report by April 30, 2014 and, assuming final
adoption of the proposed regulation, its first ORSA report by December 1, 2015.
Federal Banking Regulation
In January 2013, Ameriprise Bank received approval for and completed the conversion from a federal savings bank to a
limited powers national trust bank, which was renamed Ameriprise National Trust Bank. 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 as well as the implementation of the Dodd-Frank Act have significantly enhanced these rules
and regulations.
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, including client and employee information. 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. We continue our
efforts to safeguard the data entrusted to us in accordance with applicable laws 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 only the data that is necessary to properly achieve our business objectives and to best serve our
clients.
Environmental Laws
As the owner and operator of real property, we are subject to federal, state and local environmental laws and regulations.
Inherent in owning and operating real property are the risks of environmental liabilities and the potential expenses for
required clean-ups. We periodically conduct environmental reviews on our own real estate as well as investment real estate
to assess and ensure our compliance with these laws and regulations.
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
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