ARTICLE
30 June 2016

US Board Of Governors Of The Federal Reserve System Finalizes Regulatory Reporting Requirements For Intermediate Holding Companies Of Foreign Banking Organizations

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A&O Shearman

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The Federal Reserve Board also extends the IHC's first filing date of the FR Y-15 form to December 5, 2016 to allow institutions time to facilitate accurate reporting.
United States Finance and Banking

On June 1, 2016, the US Board of Governors of the Federal Reserve System adopted a proposal to extend various regulatory reporting requirements to US intermediate holding company (IHC) subsidiaries of foreign banking organizations. The final reporting requirements are generally the same as the proposal, with a few adjustments and clarifications. Under the final requirements, the Federal Reserve noted that it will consider requests to modify the financial data for previous years that an IHC would be required to report, or extend the time period by which an IHC would have to report the historical data on the applicable Form FR Y-14. The FR Y-14 series of reports generally collects data for stress-testing purposes. The Federal Reserve Board also clarified that it is not requiring at this time that the FR Y-14 attestation requirement apply to IHC subsidiaries of US bank holding companies subject to the Large Institution Supervision Coordinating Committee. The Federal Reserve Board also extends the IHC's first filing date of the FR Y-15 form to December 5, 2016 to allow institutions time to facilitate accurate reporting.

The final rule is available at: https://www.gpo.gov/fdsys/pkg/FR-2016-06-01/pdf/2016-12867.pdf.

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