Enhanced Prudential Standards for Foreign Banking Organizations U.S. OperationsThe Dodd-Frank "Quid Pro Quo"
By LAWRENCE D. KAPLAN
This client alert discusses recent guidance issued by the Federal Reserve Board regarding the Agency's new supervisory regime imposed on Foreign Banking Organizations with significant U.S. operations. The alert highlights the Federal Reserve's rationale for imposition of the new requirements, and provides a detailed analysis of the new enhanced prudential standards. Of particular note are the requirements imposed on the largest foreign banks operating in the U.S., including a requirement that such banks restructure their U.S. operations into a new intermediate holding company that will be directly supervised by the Federal Reserve.