A Dramatic Departure? National Treatment of Foreign Banks
April 1, 2015
The Clearing House’s Banking Perspective recently published the article, “A Dramatic Departure? National Treatment of Foreign Banks” in its Q1 – 2015 issue. Authored by Cleary Gottlieb partner Derek Bush, this article covers one of the most controversial elements of the Federal Reserve Board’s implementation of enhanced prudential standards for foreign banking organizations (FBOs)—the requirement that FBOs with $50 billion or more in U.S. non-branch assets to restructure the ownership of their U.S. subsidiaries into a single “intermediate holding company,” regulated as a U.S. bank holding company whether or not it owns a U.S. bank.
