Federal Reserve proposes enhanced supervision for U.S. operations of foreign banking organizations

On December 14, 2012, the Federal Reserve Board (the “Board”) issued a notice of proposed rulemaking (the “Proposal”) that would implement the enhanced prudential standards and early remediation requirements in sections 165 and 166 of the Dodd-Frank Wall Street Reform and Consumer Protection Act for foreign banking organizations with total global consolidated assets of $50 billion or more and foreign nonbank financial companies supervised by the Board. This update provides a summary of the key aspects of the Proposal which would become effective on July 1, 2015. Interested parties have until March 31, 2013 to submit comments on the Proposal to the Board.