On 18 February 2014, the Board of Governors of the Federal Reserve System approved a final rule implementing certain of the ‘enhanced prudential standards’ mandated by Section 165 of the Dodd-Frank Act. The Final Rule applies the enhanced prudential standards to US bank holding companies with $50bn or more in total consolidated assets and the US banking presence of foreign banking organisations (FBOs). The Final Rule is certainly an important new regulation for large US banking organisations. But it also represents a significant development for non-US banking organisations that have operations in the US.
FW spoke to Jeff Berman at Clifford Chance, Robin Maxwell at Linklaters and Brian D. Christiansen at Skadden, Arps, Slate, Meagher & Flom, about the new regime.
TalkingPoint: Enhanced prudential standards for banks in the US