The Federal Reserve has issues frequently-asked questions (FAQs) designed to clarify the FRB’s views on the implementation, governance, and strategic challenges confronting foreign banking organizations (FBOs) following the FRB’s tough new rules for them. Although the clarifications reduce uncertainty and, thus, legal and reputational risk, they also make clear that the Board is taking a stringent view of the new FBO framework, especially for large-FBO intermediate holding companies.
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