Gibson Dunn discusses The Federal Reserve’s Section 165 Rule for Foreign Banks

On February 18th, the Board of Governors of the Federal Reserve System (Federal Reserve) voted unanimously to approve a final rule (Final Rule) implementing the enhanced prudential standards contained in Section 165 of the Dodd-Frank Act.  This Client Alert discusses the Final Rule as it applies to non-U.S. banks that are “foreign banking organizations” under the Federal Reserve’s regulations (FBOs).

As expected, the Final Rule breaks sharply from the Federal Reserve’s historical treatment of FBOs by requiring those FBOs with $50 billion or more in total global consolidated assets and $50 billion or more in total U.S. non-branch/agency assets (non-branch … Read more