The Federal Reserve Board (“Fed”) approved a final rule on November 22 that requires U.S. bank holding companies with total consolidated assets of $50 billion or more (“BHCs” or “covered BHCs”) to submit an annual capital plan to the Fed for review and to request prior approval in certain circumstances before making a capital distribution. BHCs that receive a notice of objection to their submitted capital plan will not be permitted to make a capital distribution until the objection is cleared.