Section 204 of the Gramm-Leach-Bliley Act added a new subsection (t) to section 18 of the Federal Deposit Insurance Act requiring the Federal Reserve Board (Board), in consultation with the Securities and Exchange Commission (SEC), to establish record-keeping requirements for state member banks and branches and agencies of foreign banks that rely on the exceptions from the definition of "broker" or "dealer" provided in section 3(a)(4) or (5) of the Securities Exchange Act of 1934 (Exchange Act). The Board and the SEC, as required by the Financial Services Regulatory Relief Act of 2006, issued joint final rules implementing the "broker" exception in section 3(a)(4) of the Exchange Act (October 3, 2007, 72 FR 56514). As part of the final rulemaking, a bank is exempt from compliance with the definition of "broker" until the first day of the bank's first fiscal year commencing after September 30, 2008. The Board and other Federal banking agencies, in consultation with the SEC, are developing rules to implement the statutory record-keeping requirement, which will be proposed for public comment. It is not anticipated that the Board's proposal, when issued, would have a significant economic impact on a substantial number of small entities subject to the Board's regulation.