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


Head of Bank Regulatory Practice



Philip A. Aquilino

Managing Director

Financial Services Regulatory Practice


Jim Negus


U.S. Lead Capital Management Practice



Howard L. Margolin


Capital Markets, Dodd Frank Act Implementation


Barbara Federowicz

Managing Director

Risk Consulting, Legal Entity Rationalization



Anthony G. Marsicovetere

Managing Director

Global Banking Tax




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Jitendra Sharma

Jitendra Sharma
Global Leader
Financial Risk Management
New York
+1 212-872-7604

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