The FRB and FDIC today took totally different tacks in their assessment of the resolution plans filed by large U.S. regional BHCs and the intermediate holding companies (IHCs) formed by four foreign-domiciled GSIBs.  Although none of the large IHCs that filed so far flunked, the Board and FDIC unanimously cited each for failings that not only put these banks on notice, but reconfirm our prior advisory:  large foreign banks doing business in the U.S. get extra scrutiny despite the new FBO framework because of continuing U.S. fears about home-country regulatory requirements and the often very different resolution regimes applying to parent banks.  Guidance today indicates not only that the standards applied to U.S. GSIBs (see Client Report LIVINGWILL11) will be applied to GSIB IHCs going forward, but also that these are tougher still and in many ways reach directly to branches otherwise not consolidated with the IHC.

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