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December 21, 2012

Federal Reserve Proposes Enhanced Prudential Standard and Early Remediation Requirements for U.S. Operations of Foreign Banks

Arnold & Porter Advisory

On December 14, 2012, the Board of Governors of the Federal Reserve System approved for issuance a proposed rule and request for public comment to implement provisions of Sections 165 and 166 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 related to foreign banking organizations. Sections 165 and 166 generally require the Board to impose enhanced prudential standards on bank holding companies, including foreign banking organizations with a banking presence in the United States, with total consolidated assets of US$50 billion or more and on nonbank financial companies designated for Board oversight by the Financial Stability Oversight Council (Council). This Advisory deals solely with the proposed regulations' impact on affected foreign banking organizations.

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