The Bank Policy Institute and American Bankers Association on June 21 jointly filed a comment letter with the Federal banking agencies on two proposals to tailor regulations for foreign banking organizations (FBOs). The letter argues that the final rules should rely upon the characteristics of an FBO’s intermediate holding company (IHC) — rather than its combined U.S. operations (CUSO) — to determine requirements that apply at the IHC level, and that the agencies should adopt the general framework of the proposals’ risk-based indicator approach, subject to deploying it so that an IHC’s characteristics determine IHC-level requirements, and to other important changes to the risk-based indicators that would more appropriately reflect the risk profiles of applicable FBOs. The letter further urges the agencies not to impose standardized liquidity requirements on FBOs with respect to their U.S. branch and agency networks.
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