SIFMA Comment on Proposals Revising Applicability of Enhanced Prudential Standards for Foreign Banking Organizations

02/07/2019 | EIFR

Dear Sirs and Madams:

The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates the opportunity to comment on the following proposals by the federal banking agencies (the “Agencies”) to revise the enhanced prudential standards that apply to foreign banking organizations (“FBOs”):

• the proposed rule of the Board of Governors of the Federal Reserve System (the “Board”) to revise Regulation YY (the “Board Proposal”);2 and
• the Agencies’ proposed rule to revise interagency liquidity and capital requirements (the “Interagency Proposal,” and together with the Board Proposal, the “Proposals”).3

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