September 13, 2019

The Federal Reserve’s FBO Tailoring

President Trump signed the Economic Growth, Regulatory Relief, and Consumer Protection Act (“EGRRCPA”) into law in May 2018.  The EGRRCPA modified many provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) to “tailor” the prudential framework for banking organizations and to provide, among other things, regulatory relief for a range of banking organizations, primarily, but not exclusively, focused on $250 billion asset and smaller firms. 

The Federal Reserve Board (the “FRB”) and the other federal banking agencies issued in October 2018 proposals that would modify the prudential framework for U.S. banking organizations (the “Domestic  Proposal”) and then issued separate proposals in April 2019 for changes to the prudential framework applicable to international banking organizations (the “FBO Proposal”).     

This panel will discuss:

  1. the U.S. regulatory approach to regulating international banks in the United States;
  2. the impact of the FBO Proposal on international banks in the context of how international banks are structured and operate in the United States;
  3. the impact of the FBO Proposal on the global banking system; and
  4. the current global conversation on ending “too big to fail” and balancing home/host country regulation.
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