In my January 2013 column,1 I discussed a Notice of Proposed Rulemaking issued by the Board of Governors of the Federal Reserve System (FRB) proposing enhanced prudential standards on non-U.S. banking organizations with banking operations in the United States. The regulations are required under section 165 of the Dodd-Frank Wall Street Reform and Consumer Protection Act.2 The comment period ended on April 30, 2013, having been extended from March 31.
Commenters included non-U.S. banks, trade associations and other interest groups. While FRB staff will review all of the comments submitted (56 were posted to the FRB’s website as of May 5, 2013), some comments undoubtedly will be scrutinized even closerthose of the FRB’s fellow regulators. This month’s column will review their comments and concerns.
Brief Recap
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