Dodd-Frank for Foreign Banks

On December 14, 2012, the Federal Reserve Board proposed a set of new prudential standards and early remediation requirements applicable to Foreign Banking Organizations (FBOs)1 having significant presence in the
United States. One primary effect of the proposed rules is the closing of current gaps in the supervision and regulation of FBOs, reflecting a shift from long standing country by country supervision.

The timing of the new proposed standards for FBOs may hardly come as a surprise

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