Fed Extends Comment Period On Enhanced Prudential Standards Rule

On January 5, 2012, the Federal Reserve Board ("FRB") published in the Federal Register a notice of proposed rulemaking (77 Fed. Reg. 594 (Jan. 5, 2012)) that would implement the enhanced prudential standards required to be established under Section 165 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act"), and the early remediation requirements established under Section 166 of the Dodd-Frank Act. See Federal Reserve Board Toughens Oversight of SIFI's: Enhanced Prudential Standards.

The proposed rule focuses on seven areas of oversight for Systemically Important Financial Institution ("SIFI's" – larger nonbank financial companies and bank holding companies with total consolidated assets of $50 billion or more): (1) Risk-Based Capital and Leverage Requirements; (2) Liquidity Requirements; (3) Single-Counterparty Credit Limits; (4) Risk Management Requirements; (5) Stress Testing Requirements; (6) Debt-to-Equity Limits; and (7) Early