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January 03, 2019

The Federal Reserve Board's ("FRB") "clean holding company" requirements - which apply to the eight U.S. globally systemically important banks and the U.S. intermediate holding companies of the largest foreign banks operating in the United States - became effective on January 1, 2019. The requirements are applicable only to the legal entity that is the top-tier U.S. holding company and do not apply to its affiliates or subsidiaries. According to the final rule adopted by the FRB, covered holding companies generally are barred from: issuing guarantees of a subsidiary's liabilities with cross

December 21, 2018

The Office of the Comptroller of the Currency, the Federal Reserve Board, and the FDIC (collectively, the "agencies") adopted a final rule to provide banking organizations the option to "phase in over a three-year period the day-one" regulatory capital effects of the "Current Expected Credit Losses" ("CECL") methodology. In 2016, the Financial Accounting Standards Board released a new expected credit loss accounting standard which introduced the CECL for estimating allowances for credit losses. The final rule addressed changes to credit loss accounting under U.S. generally accepted accounting