As promised, the Federal Reserve Board today approved two proposals “tailoring” prudential standards for foreign banking organizations (FBOs) and an additional NPR to realign living-will planning requirements for large banks. Consistent with her growing opposition to pending regulatory revisions, Gov. Brainard opposed both of these changes. As discussed in this report, she believes that the proposed application of the LCR (see FSM Report LIQUIDITY17) and NSFR (see FSM Report LIQUIDITY26, presumably upon U.S. finalization) to intermediate holding companies (IHCs) is necessary, but insufficient because liquidity standards would still not apply to foreign branches and agencies. While Gov. Brainard supports some of the living will timing and threshold changes required by law (see FSM Report SIFI27), she opposes what she believes to be the slow pace of filings demanded of banks over $250 billion. She also opposes the proposed process for allowing large banks (including GSIBs) to request waivers from resolution plan requirements that would be automatically approved unless both the FRB and FDIC objected.
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