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November 28, 2012

Federal Reserve Governor Daniel K. Tarullo gave a speech discussing what he termed a "practical and reasonable way forward" in the U.S. regulation of foreign banking organizations. In Governor Tarullo's speech, delivered at the Yale School of Management, he noted that the profile of foreign bank operations in the United States changed significantly in the run-up to the financial crisis (see also attached study), shifting from a "lending branch" model to a "funding branch" model, in which U.S. branches of foreign banks began borrowing large amounts of U.S. dollars "to upstream to their parents

April 03, 2013
Commentary by Scott Cammarn

The Federal Reserve Board is adopting a final rule to establish, for purposes of Dodd-Frank Title I, the following: (i) requirements for determining if a company is "predominantly engaged in financial activities," and (ii) definitions of the terms "significant nonbank financial company" and "significant bank holding company." These terms are relevant to various provisions of Title I, including Section 113 ("Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies"), which authorizes the Financial Stability Oversight Council ("FSOC") to designate a nonbank

February 18, 2014
Commentary by Scott Cammarn

The Board of Governors of the Federal Reserve System ("FRB") approved final amendments to Regulation YY to implement certain of the enhanced prudential standards required to be established under Dodd-Frank Section 165 ("Enhanced Supervision and Prudential Standards for Nonbank Financial Companies Supervised by the Board of Governors and Certain Bank Holding Companies"). The enhanced prudential standards include risk-based and leverage capital requirements, liquidity standards, requirements for overall risk management, stress-test requirements, and a 15-to-1 debt-to-equity limit for companies

March 03, 2015

Vice Chair of the Federal Deposit Insurance Corporation ("FDIC") Thomas M. Hoenig spoke at the Institute of International Bankers' Annual Washington Conference about the principles of effective financial supervision. Mr. Hoenig explained that the best ways to judge a firm's risk profile are through a strong supervisory program and an equally strong examination process, which include assessing a firm's "liquidity, operations, balance-sheet strength, asset quality, and management." He noted that although large insured banks are considered too complex for full-scope examinations, sampling

September 23, 2015
Commentary by Steven Lofchie

The Financial Stability Board ("FSB"), the Basel Committee on Banking Supervision ("BCBS"), the Committee on Payments and Markets Infrastructures ("CPMI") and IOSCO released a 2015 central counterparties ("CCPs") workplan and a progress report detailing the agencies' efforts to enhance the "resilience, recovery planning and resolvability" of CCPs. The workplan focuses on CCPs that are systemic across multiple jurisdictions.