In a recent speech, Federal Reserve Governor Daniel Tarullo previewed a potential proposal that would require foreign banks with large U.S. operations to create a separately capitalized, top-tier U.S. intermediate holding company that would sit on top of all U.S. bank and nonbank subsidiaries and that would have to independently meet U.S. capital, liquidity and other Dodd-Frank prudential standards. Large U.S. banks will need to also focus this proposal, since it would be another step on the road to subsidiarization and, if implemented, could well lead to a further push by major foreign regulators to impose similar requirements for U.S.-headquartered banks.

SIFMA will hold a Member briefing on Thursday, Dec. 6, at 12 p.m. EST to discuss the implications for both foreign banks and U.S.-headquartered banks. Pre-registration for this call is required. Participants can register by visiting this pre-registration link. The Conference ID Number is 10022036. A dial-in number will be provided upon completion of the pre-registration process. This call is closed to the press and non-members. To check your firm's membership status check the following membership directories: SIFMA Full Members, SIFMA Associate Members, or contact SIFMA's Office of Member Engagement at 212-313-1152 or inquiry@sifma.org.