The Federal Reserve Board ("FRB") proposed to implement the "tailored" application of the prudential requirements to foreign banking organizations ("FBOs"). In addition, the FRB, the Office of the Comptroller of the Currency and the FDIC proposed a joint regulation to apply the capital liquidity requirements to the U.S. operations of foreign banks. Finally, the FRB and the FDIC issued ‎a proposed regulation that would amend the resolution planning (or "living will") requirements as applied to the U.S. operations of FBOs. A full summary will be provided in an upcoming Cabinet newsletter.

The Trump administration designated Iran's Islamic Revolutionary Guard Corps ("IRGC") as a Foreign Terrorist Organization ("FTO"), making it the first time that the United States has designated part of another government as an FTO. The Trump administration asserted that the designation will increase financial pressure on the regime and deprive it of necessary resources to fund terrorist activities. The action puts businesses and other governments "on notice" with respect to the nature of the IRGC, which "operates front companies and institutions around the world to fund terror." The action

FINRA proposed to extend the pilot period relating to FINRA Rule 6121.02 ("Market-Wide Circuit Breakers in NMS Stocks") until October 18, 2019. FINRA filed the proposal for immediate effectiveness and noted that it will file a separate proposal to operate Rule 6121.02 on a permanent basis.

The SEC corrected a rule document published in the Federal Register concerning the final amendments to Regulation S-K and related rules and forms. The correction referred to a section number in a table text entry. As previously covered, the rule changes - which are intended to reduce disclosure burdens on registrants - will generally go into effect on May 2, 2019.

A Federal Reserve Board, the FDIC and the Office of the Comptroller of the Currency proposal requiring U.S. global systemically important banking organizations ("GSIBs") to hold additional capital against the holdings of total loss-absorbing capacity ("TLAC") debt issued by other GSIBs was published in the Federal Register. Comments must be submitted by June 7, 2019 ( see prior coverage).