Potential SIFIs Take Note – Your Future Is Being Decided Now: FRB Prepares to Act on Enhanced Prudential Standards

February 16, 2012
The Federal Reserve Board has issued proposed rules under the Dodd-Frank Act establishing enhanced prudential standards and early remediation requirements (“Enhanced Standards”) for large bank holding companies and systemically important financial institutions (“SIFIs”). The Enhanced Standards have not received as much attention as proposed rules for designating nonbank financial companies as SIFIs, but the Enhanced Standards may be finalized before the first SIFI is designated. This update highlights the significant impact that the Enhanced Standards may have, particularly on companies designated as SIFIs.