ARTICLE
5 October 2016

US Board Of Governors Of The Federal Reserve System Proposes Expansion Of Chief Financial Officer Attestation To Intermediate Holding Companies

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A&O Shearman

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The FRB published a proposal to extend the Capital Assessments and Stress Testing information collection applicable to bank holding companies with total consolidated assets of $50 billion or more...
United States Finance and Banking

On July 28, 2016, the Federal Reserve Board published a proposal to extend for three years, with revision, the Capital Assessments and Stress Testing information collection applicable to bank holding companies with total consolidated assets of $50 billion or more and US intermediate holding companies established by foreign banking organizations. The Federal Reserve Board proposed revising the FR Y-14A, Q and M schedules to expand the chief financial officer attestation reporting requirement applicable to US BHCs subject to the Large Institution Supervision Coordinating Committee (LISCC) framework to US IHC respondents on a phased-in basis beginning with reports as of December 31, 2017. The CFO-attestation requirement was finalized for US BHCs earlier this year and implementation is required on a phased-in basis for reports as of December 31, 2016.

The proposal also provides for revisions to the FR Y-14A that include data on the supplementary leverage ratio as well as to include information on material operational risks included in loss projections, operational risk scenarios and updated documentation requirements to align with SR Letter 15-18. Comments were due by September 26, 2016.

The Federal Reserve Board proposal is available at: https://www.gpo.gov/fdsys/pkg/FR-2016-07-28/pdf/2016-17876.pdf .

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