Dodd-Frank: Enhanced Supervision Becomes Final

The Federal Reserve’s proposed requirements for large US and non-US banking organizations to comply with enhanced supervisory requirements, required by Section 165 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, were adopted in final form on February 18 in substantially the form proposed. Several revisions address negative comments, in some cases providing significant relief, but the general requirements were unchanged. Final implementation dates were extended in order to give affected organizations additional time to come into compliance.

The original proposals were issued in December 2011 for domestic organizations and December 2012 for non-US ones. The final regulation (“Final Regulation”) covers both proposals in a revised version of Regulation YY.

Please see full memo below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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