ARTICLE
6 June 2020

FRB Extends Compliance Dates For Single-Counterparty Credit Limits

CW
Cadwalader, Wickersham & Taft LLP

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The FRB noted that the extension does not affect the compliance dates regarding the SCCL applicable to U.S. intermediate holding companies of FBOs.
United States Finance and Banking

The Federal Reserve Board ("FRB") extended by 18 months the initial compliance date for a final rule imposing single-counterparty credit limits ("SCCL") for bank holding companies and certain foreign banking organizations ("FBOs"). In light of the extension, and regarding the SCCL applicable only to an FBO's combined U.S. operations:

  • FBOs that have the characteristics of a global systemically important banking organization ("G-SIB") need to comply with the SCCL by July 1, 2021; and
  • All other FBOs need to comply with the SCCL by January 1, 2022.

As previously covered, the FRB final rule was adopted to implement SCCL for U.S. bank holding companies and FBOs operating in the United States with $250 billion or more in total global consolidated assets. The limits also apply to any G-SIB, as well as to any FBO's U.S. intermediate holding companies with $50 billion in total consolidated assets.

The FRB noted that the extension does not affect the compliance dates regarding the SCCL applicable to U.S. intermediate holding companies of FBOs.

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