In my March 2017 column, various executive orders emanating from the Trump White House starting shortly after inauguration that began the president's deregulation initiative were discussed.¹ Executive Order 13772 sets out administration policy to regulate the U.S. financial system consistent with seven “core principles,” and tasked the Secretary of the Treasury to report to the President on the extent to which current U.S. financial regulatory requirements promote and support the core principles or are inconsistent with them.² On June 12, 2017, Treasury Secretary Steven Mnuchin issued his report.³

While the report has something for banks large and small, this column will focus on the recommendations that would appear to be more relevant to non-U.S. bank operations in the United States. A non-U.S. bank with U.S. banking operations, such as a direct branch or agency, or commercial bank subsidiary, generally is treated as a U.S. holding company under most U.S. bank holding company laws and regulations.

As with the executive orders, it should be noted that mere issuance of this report does not change the current regulatory landscape. Any changes based on the report will need statutory or regulatory changes.