• Federal Reserve Board Proposes Rules Regarding Enhanced Prudential Standards and Early Remediation Requirements for Foreign Banking Organizations and Foreign Nonbank Financial Companies
  • December 28, 2012
  • Law Firm: Kilpatrick Townsend Stockton LLP - Atlanta Office
  • The Federal Reserve Board (“FRB”) published in the Federal Register on December 28, 2012 proposed rules that would amend Regulation YY (Enhanced Prudential Standards) (the “Proposal”) to implement the enhanced prudential standards required to be established under section 165 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”). In addition, the Proposal addresses the early remediation framework required to be established under section 166 for foreign banking organizations (“FBOs”) with total consolidated assets of $50 billion or more and foreign nonbank financial companies supervised by the FRB. The FRB stated that the proposed rules would implement the long standing policy of national treatment and maintaining equality of competitive opportunity between the U.S. operations of FBOs and U.S. banking firms. However, the proposal also would make significant incursions into the supervision of FBOs by their own home country authorities.