On 23 November 2016 the European Commission published a package of proposals amending the Capital Requirements Directive and associated Regulation (CRD and CRR, together CRD IV), the Bank Recovery and Resolution Directive (BRRD) and the Single Resolution Mechanism (SRM) Regulation. The proposal is intended to implement global standards set by the Financial Stability Board (FSB) and the Basel Committee on Banking Supervision (BCBS). To facilitate the resolution process for material EU activities of non-EU banking groups, it is proposed to require them to establish an intermediate EU parent undertaking (EUPU). This new rule can be seen as a response to the US requirement for an intermediate holding company (IHC) for US operations of non-US banks with more than US$50bn of assets.
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