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ARTICLE · 18 NOVEMBER 2019

Agencies Adopt Final Rules Tailoring Enhanced Prudential Standards

Cleary Gottlieb Steen & Hamilton LLP
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The Federal Reserve Board and Federal Deposit Insurance Corporation have released two final rules to tailor the application of enhanced prudential standards to large U.S. and foreign banking organizations.

United StatesFinance and Banking

The Federal Reserve Board and the Federal Deposit Insurance Corporation1 have released two final rules to tailor the application of enhanced prudential standards to large U.S. and foreign banking organizations:

  • A Board-only release that finalizes the application of enhanced prudential standards (stress testing, capital planning, liquidity stress testing, liquidity risk management, single counterparty credit limits and overall risk management) to U.S. bank holding companies, certain savings and loan holding companies and FBOs; and
  • A joint release tailoring the application of capital and liquidity rules to these banking organizations.

The Final Rules leave in place the core post-crisis regulatory framework created by the Dodd-Frank Act, while creating tiered thresholds that modify the stringency and applicability of the regulations. Notwithstanding significant comments about how the proposals could have been made more risk-sensitive, the Agencies opted for

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