Bank Capital Plans and Stress Tests: Federal Reserve Board Proposes Reporting Requirements for the Intermediate Holding Companies of Foreign Banking Organizations

Sullivan & Cromwell LLP - February 11, 2016

On February 2, 2016 the Federal Reserve issued proposed reporting requirements (the “Proposal”) for the U.S. intermediate holding companies (“IHCs”) to be formed by certain foreign banking organizations (“FBOs”) no later than July 1, 2016. The Proposal would require IHCs to submit various Federal Reserve regulatory reports, including reports on forms FR Y-6, FR Y-9C, FR Y-14A/Q/M, FR Y-15, and FR 4200 and 4201, beginning with the reporting period ending September 30, 2016 for most reports.