Alerts

Federal Reserve Proposes Enhanced Prudential Standards and Early Remediation Requirements

January 11, 2012

Moving forward on what many consider to be the most important and most significant part of the Dodd-Frank Wall Street Reform and Consumer Protection Act, on Dec. 20, 2011 the Board of Governors of the Federal Reserve System proposed rules (the “Proposed Regulation”) to impose greater regulation and supervision on:

• U.S. bank holding companies with $50 billion or more in consolidated assets; and
• Non-bank financial companies (U.S. and non-U.S.) designated as “systemically important” by the Financial Stability Oversight Council.

This Memorandum summarizes the Proposed Regulation. Interested parties have until March 31, 2012 to submit comments to the Board (including in response to the 95 explicit questions asked by the Board).