Foreign Banking Organizations & the Intermediate Holding Company Rule 



KPMG LLP sponsored a Share Forum on Feb. 19, 2013, to discuss the Federal Reserve Board’s (Board) December 2012 proposed rule (NPR), which would introduce new regulatory requirements on foreign banking organizations (FBOs) with $50 billion or more in consolidated assets that operate in the United States.

These requirements would implement the enhanced prudential standards and early remediation requirements imposed by Sections 165 and 166 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. A proposed requirement for certain FBOs ($50 billion or more in consolidated assets and $10 billion or more in U.S. assets) to form a U.S. intermediate holding company (IHC) would serve as a supplemental enhanced prudential standard.


Compliance is proposed to commence July 2015; comments are requested by April 30, 2013.


Key activities FBOs will need to address:


  • Respond to Board’s NPR
  • Develop an Implementation Plan
  • Establish Strong Program Management
  • Perform Impact and Scenario Analysis
  • Implement Program Components including:
    • Regulatory Implications: Capital, Liquidity, Reg W, etc.
    • Infrastructure: Systems and Data
    • Stress Testing
    • Regulatory Reporting
    • Process and Controls
    • Tax Implications

Hugh C. Kelly

Principal

Head of Bank Regulatory Practice

202-523-5200

hckelly@kpmg.com

 

Philip A. Aquilino

Managing Director

Financial Services Regulatory Practice

703-286-8029

paquilino@kpmg.com

Jim Negus

Principal

U.S. Lead Capital Management Practice

213-955-8507

jtnegus@kpmg.com

 

Howard L. Margolin

Partner

Capital Markets, Dodd Frank Act Implementation

212-954-7863

hmargolin@kpmg.com

Barbara Federowicz

Managing Director

Risk Consulting, Legal Entity Rationalization

212-872-2179

bfederowicz@kpmg.com

 

Anthony G. Marsicovetere

Managing Director

Global Banking Tax

212-954-2053

amarsicovetere@kpmg.com

 

 

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Contact

Jitendra Sharma

Jitendra Sharma
Global Leader
Financial Risk Management
New York
+1 212-872-7604
jitendrasharma@kpmg.com

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