Client Alert

On February 18, 2014, the Federal Reserve issued the final version of new Regulation YY establishing “enhanced prudential standards” for large bank holding companies and large foreign banks operating in the United States. The first part of this client alert describes the Regulation YY requirement that certain foreign banks operating in the US establish an “intermediate holding company.” The second part describes (1) additional “enhanced prudential standards” that will apply to such IHCs and (2) separate standards that will apply to the US operations of any foreign bank with $50 billion or more in US assets, including foreign banks required to establish IHCs.

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