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17.06.2009

US Regulatory White Paper

Hot on the heels of the FSA Rules on Liquidity Risk, changes to the regulatory landscape with the Fed. In a recent White Paper from the US Treasury Department they discuss on Page 9

"Consolidated supervision of a Tier 1 FHC should extend to the parent company and to all of its subsidiaries - regulated and unregulated, US and foreign.....the constraints that the Gramm-Leach-Bliley Act (GLB Act) introduced on the Federal Reserve's ability to require reports from, examine, or impose higher prudential requirements or more stringent activity restrictions on the functionally regulated or depository institution subsidiaries of FHCs should be removed"

Powerful stuff

Consultation is taking place and the rules will not be in place before the FSA Regime comes into play - even with the delays enivsaged in FSA CP09.14, but its clear that around the world in the major financial centres, being a foreign owed branch or subsidiary just got a lot more complicated

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