The Board of Governors of the Federal Reserve System (the “Fed”) has released for public comment proposals to tailor (i) the enhanced prudential standards that apply to larger foreign banking organizations (“FBOs”) and (ii) the resolution planning requirements that apply to larger FBOs and larger US bank and holding companies (collectively, “larger banking organizations”). The proposals are part of the Fed’s broader effort to implement the 2018 Economic Growth, Regulatory Relief, and Consumer Protection Act and to request comment on whether the Fed should impose standardized liquidity requirements on US branches and agencies, as well as on two potential approaches for doing so.

The proposals seek to tailor the application of the enhanced prudential standards and resolution planning requirements based on a larger banking organization’s US risk profile and, in doing so, eliminate many requirements for certain larger and midsize banking organizations. The centerpiece of the proposal is a system of categories that would identify FBOs with certain US risk profiles and apply defined sets of standards to each category. During our call, we will examine:

  • The proposed system of categories and standards that will apply to each category
  • The request for comment on liquidity requirements for US branches and agencies of FBOs
  • Revisions to the resolution planning requirements for larger banking organizations

Please join Mayer Brown partners David Sahr, Don Waack and Jeffrey Taft and senior associate Matthew Bisanz to hear more about this important development.

Mayer Brown’s Global Financial Markets Initiative helps clients deal with the legal and business challenges resulting from the ongoing turbulence in worldwide financial markets. By mobilizing the firm’s global resources from multiple practices and offices, the initiative provides clients with knowledgeable and timely counsel on a broad spectrum of their legal needs.

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Listen to: Federal Reserve Issues Tailoring Proposals for FBOs and Resolution Planning Requirements