金融控股公司法頒訂施行後，金融控股公司如雨後春筍般地林立，隨著金融控股公司規模日益龐大，其影響力勢必漸增，在監理、控管方面，則不得不予以強化－尤以「防火牆」為要，然亦不應過度規範、限制而波及金融控股公司成立所欲達成之3C經營綜效（有效的資本管理、跨售及降低成本），因此，金融控股公司法第45條有關「授信以外交易」之規定有其訂定之必要，惟亦應顧及金融控股公司之立場，如對於其實務運作已然產生障礙時，則本條規定應予調整，以符實務所需，本文乃就此提出著者淺見，以供實務上及未來修法之參考。 After the Financial Holding Company Act was stipulated, the financial holding companies were established more and more. Because the scale of the financial holding company is more enormous, the influence of the financial holding companies is more powerful. Therefore, the functions of regulation and control for the financial holding company would be strengthened, but it couldn’t endanger the 3C operational synergy（capital efficiency, cross sales and cost down）of the financial holding company. Although the "transactions other than credit extension" as provided in the Article 45 of the Financial Holding Company Act is necessary to be stipulated, the situation of the financial holding company should be emphasized. In the event that the operation of the financial holding company has become difficult, the Article 45 of the Financial Holding Company Act might be justified in order to satisfy the necessity to process the business. The author has some humble opinions in this paper and wishes the foregoing opinions would be the reference in the operation of the financial holding company and the modification of the Financial Holding Company Act.