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FRB Proposes Extending Compliance Dates for Single-Counterparty Credit Limits

The Federal Reserve Board ("FRB") proposed extending the single-counterparty credit limit compliance dates for foreign banking organizations.

As previously covered, the FRB approved a final rule to implement single-counterparty credit limits for U.S. bank holding companies and foreign banking organizations operating in the United States with $250 billion or more in total global consolidated assets. The limits also apply to any global systemically important banks ("GSIBs"), as well as any foreign banking organization's U.S. intermediate holding companies with $50 billion in total consolidated assets.

The final rule became effective on October 5, 2018. The initial compliance date for (i) a foreign banking organization with the characteristics of a GSIB was set for January 1, 2020 and (ii) any other foreign banking organization was set for July 1, 2020. For the single-counterparty credit limits applicable to a foreign banking organization's combined U.S. operations only, the FRB is now proposing to extend the initial compliance dates for foreign banking organizations with the characteristics of GSIBs and other foreign banking organizations to July 1, 2021 and January 1, 2022, respectively. The FRB is not proposing any modification or amendment of the initial compliance dates in the final rule regarding the single-counterparty credit limits applicable to any U.S. intermediate holding company of a foreign banking organization.

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