Institute of International Bankers Dodd-Frank Section 165 Seminar
March 26, 2014
New York, NY
On March 26, 2014, Cleary Gottlieb partner Derek Bush moderated two panels at the IIB’s Dodd-Frank Seminar “Application of Enhanced Prudential Standards to Foreign Banking Organizations Under Section 165 of DFA.”
The first panel provided an overview of the final implementing regulations applying Section 165 to Foreign Banking Organizations in the context of how the new regime departs from the Federal Reserve’s long-standing regulatory framework for FBOs, the tension it creates with existing international agreements and the home-country supervision of cross-border banking organizations. The second panel discussed issues associated with the requirement that the largest FBOs move their U.S. broker-dealer and other nonbranch operations under separately capitalized intermediate holding companies (IHCs) that will be subject to U.S. bank capital requirements and liquidity buffers.