Federal Reserve takes aggressive position on non-US banks
The board of governors of the Federal Reserve System recently issued a final rule that will fundamentally change the way in which non-US banks are regulated and supervised in the US.
Pursuant to section 165 of the Dodd-Frank Act, the Federal Reserve has issued regulations for the enhanced prudential supervision of large bank holding companies (i.e. those that hold $50bn or more of total consolidated assets). Section 165 applies generally to covered financial institutions regardless of where they are organised, but the Federal Reserve has decided to apply its provisions to non-US banks much more aggressively than its manner of supervising foreign banks in the past.
In particular, every non-US bank with a substantial presence in the US (i.e. those that hold $50bn or more of total US assets, not including assets held in US branches and agencies) will be required to establish an intermediate holding company (IHC) to hold its US-based banking and non-banking subsidiaries…
Click on the link below to read the rest of the Allen & Overy briefing.
News from Allen & Overy
News from The Lawyer
Briefings from Allen & Overy
This year is expected to be a bumper year for pension risk transfer in the UK.
The OFAC has imposed a new set of ‘sectoral sanctions’ against two Russian energy firms and two Russian banks pursuant to Executive Order 13662.
Analysis from The Lawyer
At the time of its launch Accutrainee was described as a revolutionary change to the training model. Has it proved to be so? Not really.
Shearman & Sterling is making its presence felt in the City, squaring up to magic circle firms and looking to muscle in on key relationships. Private equity house Bridgepoint is one outfit that has had its head turned by the US firm.