News & Analysis as of

Foreign Banking Organizations Federal Reserve

Morrison & Foerster LLP

Federal Banking Agencies Adopt Climate-Related Financial Risks Guidance

On October 24, 2023, the Federal Reserve Board (FRB), the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (together, the “Agencies”) released their final Principles for Climate-Related...more

White & Case LLP

Immigration Reform: The Federal Reserve should adopt the 2019 Volcker Rule revisions as the standard for how foreign banks can...

White & Case LLP on

The Board of Governors of the Federal Reserve (the "Federal Reserve") has over several decades defined when an activity engaged in by foreign banks subject to the Bank Holding Company Act of 1956 (the "BHCA"), which are thus...more

White & Case LLP

Financial Regulatory Observer – March 2019: Navigating uncertainty: Corporate governance for foreign banks in the US

White & Case LLP on

With the regulatory agenda for the US operations of foreign banks in a state of flux, Kevin Petrasic, Paul Saltzman, Glen Cuccinello, Will Giles and Alexander Abedine of global law firm White & Case provide a map to help...more

Morrison & Foerster LLP

Federal Reserve Board Revises FR Y-7 and Provides Guidance on Enhanced Prudential Standards for Foreign Banking Organizations

On January 18, 2018, the Board of Governors of the Federal Reserve System (the “Federal Reserve Board”) announced the approval of proposed revisions to the Annual Report of Foreign Banking Organizations (“FR Y-7”). The...more

A&O Shearman

Federal Reserve Board Announces Elimination of SOSA Ranking and Proposes Changes to Payment System Risk Policy

A&O Shearman on

The US Federal Reserve Board announced that it is seeking comments regarding a proposed change to its Payment System Risk Policy. In a related action, the Federal Reserve Board has also announced that it is eliminating the...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

SEC Adopts Trade Acknowledgment and Verification Rules for Security-Based Swap Transactions - On June 8, 2016, the Securities and Exchange Commission publicized the implementation of "rules that will establish timely and...more

Orrick - Finance 20/20

Federal Reserve Updates Risk Management Supervisory Guidance for Smaller FBOs

Orrick - Finance 20/20 on

On June 8, 2016, the Federal Reserve updated its Supervisory Guidance that partially supersedes SR letter 95-51, “Rating the Adequacy of Risk Management and Internal Controls at State Member Banks and Bank Holding Companies.”...more

Orrick - Finance 20/20

Banking Agencies Permit “Reduced Content” Living Wills for Smaller FBOs

Orrick - Finance 20/20 on

On June 10, 2016, the Federal Reserve Board and Federal Deposit Insurance Corporation announced they are permitting 84 foreign banking organizations (not identified) with limited U.S. operations to file “reduced content”...more

Morrison & Foerster LLP

Federal Reserve Proposes Revisions to Form FR Y-7Q to Incorporate Capital Adequacy Standard Reporting Requirements for Foreign...

On Monday, April 4, 2016, the Board of Governors of the Federal Reserve System (“Federal Reserve”) proposed a revision to Form FR Y-7Q to incorporate the capital adequacy standard reporting requirements for foreign banking...more

Morrison & Foerster LLP

TLAC, and Then Some… A Preliminary Assessment of the Federal Reserve Board’s NPR

On Friday, October 30, 2015, the Federal Reserve Board (“Board”) reaffirmed its commitment to both the bank holding company model and single point of entry resolution. In a departure from historical views of the purpose and...more

Troutman Pepper

Observation 3.0: Frequently Asked Questions and Answers on the Volcker Rule and the Implications for Foreign Banks Investing in...

Troutman Pepper on

1. Question: What is the Volcker Rule, and when does it take effect? Answer: The Volcker Rule was enacted into law as section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Lawmakers and Regulators Continue Focus on Strategies for Resolving SIFIs"

The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 contains two sets of provisions for managing the insolvency of financial institutions. First, the legislation creates an Orderly Liquidation Authority...more

Morrison & Foerster LLP

Federal Reserve Issues Guidance on Implementation Plans and Other Enhanced Prudential Standards for Foreign Banking Organizations

On June 26, 2014, the Federal Reserve Board (“Board”) published on its website responses to frequently asked questions (“FAQs”) relating to enhanced prudential standards under Section 165 of the Dodd-Frank Act and its...more

Morrison & Foerster LLP

Summary of Final Rule Imposing Enhanced Prudential Standards on FBOs

Last week, the Federal Reserve Board (the “Board”) issued its long-awaited final enhanced prudential rule (Regulation YY) under Section 165 of the Dodd-Frank Act (the “Final Rule”) for bank holding companies and foreign...more

Pillsbury Winthrop Shaw Pittman LLP

An Update on Preparing Living Wills for Foreign Banking Organizations — Exemptions and Important Strategy Considerations

This analysis updates a previous memo and incorporates advice we have received from the Federal Reserve Board (“FRB”) and the Federal Deposit Insurance Corporation (“FDIC”) regarding the preparation of living wills by covered...more

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