• Systemically Important Financial Companies: Federal Reserve Issues Proposed Rules Implementing Enhanced Prudential Supervision Regime
  • December 27, 2011
  • Law Firm: Sullivan Cromwell LLP - New York Office
  • On December 20, 2011, the Board of Governors of the Federal Reserve System (“FRB”) issued for public comment a notice (the “Notice”) of proposed rulemaking (the “Proposed Rule(s)”) implementing the wideranging enhanced prudential standards and early remediation requirements that will apply to (i) bank holding companies (“BHCs”) with $50 billion or more in total consolidated assets (“Covered BHCs”) and (ii) nonbank financial companies designated as systemically important by the Financial Stability Oversight Council (“FSOC”) (“Covered Nonbank Companies” and, together with Covered BHCs, “Covered Companies”). These rules are mandated by Sections 165 and 166 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”). The Notice is 173 pages and poses 95 specific questions. Comments are due by March 31, 2012.