Perspectives

Rethinking compliance management

Bank leaders and boards, which must come to terms with the new reality of compliance. Which “shoulds” are really sometimes “shalls?”

Perspectives

Dodd-Frank Act push-out

Banks are now focused on the decisions that they need to make and determining the best course of action to be in compliance with “push-out” in 2015.

Perspectives

Reg Pulse blog

Reg Pulse promotes the sharing of insights, experiences and perspectives on the latest regulatory developments and trends.  

Perspectives

Enhanced prudential standards

The final rule

The approval of the enhanced prudential standards represents a significant step on the part of the Fed toward improving the framework for supervising and regulating large financial institutions, both domestic and foreign. It addresses the risks that large financial institutions could pose to the financial stability of the United States.

Final rule

On February 16, 2014, the Federal Reserve Board approved a final rule strengthening the supervision and regulation of large US bank holding companies and foreign banking organizations (FBOs) under section 165 of the Dodd-Frank Act.

These final rules will likely jumpstart much of the preplanning and analysis efforts that US bank holding companies and FBOs have taken on to date. The race for implementation is next. To help kick start that race, Deloitte has developed two papers that outline changes and implications for US bank holding companies and FBOs that are designed to serve as a primer for understanding the rule’s potential impact.

 

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Domestic bank rules

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Two years into the process, domestic banks—particularly those with more than $50 billion in consolidated assets—are unlikely to find many surprises in the recent Federal Reserve (Fed) announcement on the final enhanced prudential standards (EPS) rules. Banks may already be moving down the path laid out by the Fed, particularly in the areas of capital planning, stress testing, liquidity risk management, and risk governance. Although continuing improvements and additional oversight by the board and senior management will be required, the Fed has already adopted many of these requirements (in areas such as stress testing) as part of its current supervisory toolkit.

 

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Foreign bank rules

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 As foreign banking organizations (FBOs) gain familiarity with the final enhanced prudential standards (EPS) the Federal Reserve Board (Fed) announced more than one year after the proposal, FBOs are likely to conclude that these rules usher in a new era of supervision and enforcement. After nearly a decade of the Fed administering its supervisory program for FBOs, these regulations mark a significant landmark in its oversight of foreign banks’ operations in the United States. While the Fed’s statements in past years have pointed the way to a more vigorous role in regulating FBOs through its supervisory process, these more prescriptive rules finally make it official.

 

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Meet our leaders

Irena Gecas-McCarthy

Irena Gecas-McCarthy

Principal | Banking & Securities

Irena is a principal in Deloitte & Touche LLP’s US...More

Tom Rollauer

Tom Rollauer

Director | Center for Regulatory Strategies

Tom is the executive director of Deloitte’s Center...More

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Center for Regulatory Strategies

The Deloitte Center for Regulatory Strategies provides deep knowledge and practical insight into regulatory matters across heavily regulated industries. 

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David Wright

Managing Director | Banking and Securities