Clifford Chance

Federal Reserve Proposes Enhanced Prudential Standards and Intermediate Holding Companies for Non-US Banks

18 December 2012

On December 14, 2012, the Federal Reserve Board published its proposed enhanced prudential standards for the US operations of non-US banks.  The highly anticipated proposal would implement the "rebalanced approach" to the regulation of non-US banks that Fed Governor Daniel Tarullo announced last month, respond to expected challenges in connection with the resolution of large cross border banks, and represent a marked shift in focus – away from coordinated supervision of internationally active banks at the consolidated level, and toward reduction of the risks that the cross-border activities of multinational banking organizations are thought to pose to the financial stability of host countries, particularly the United States.

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