IHC and FBOs: Intermediate Holding Companies (IHCs) & Foreign Bank Organisation FBO regime - Lombard Risk
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US Reporting for Foreign Banking Organizations

2014 Dodd-Frank enhanced prudential standards (EPS) requires a foreign banking organization with $50 billion or more in US non-branch and agency assets to establish a US intermediate holding company (IHC) over all their US subsidiaries. The IHCs are subject to US Basel III, capital planning, Dodd-Frank stress testing, liquidity, risk management requirements and other U.S. regulations. Lombard Risk AgileREPORTER provides reporting solutions for regulators reporting required by FBOs.

The 2014 Dodd-Frank enhanced prudential standards (EPS) aims to strengthen risk-based and leverage capital requirements, liquidity requirements, risk management and risk-committee requirements, resolution-planning requirements, single counterparty credit limits, stress-test requirements and a debt-to-equity limit.

Specifically, the Dodd-Frank EPS rule requires a FBO with $50 billion or more in US non-branch and agency assets to establish a US IHC over all their US subsidiaries.  The capital adequacy of foreign-owned IHCs will be addressed by standardized risk based US Basel capital rules, leverage rules (leverage ratio and supplement Leverage Ratio) and capital planning and supervisory stress testing requirements.

All IHCs are required to submit the same reports as U.S. bank and savings and loan holding companies including call reports, FRY9, FRY14 (CCAR), FR 2052a (LCR) and others.

Lombard Risk AgileREPORTER includes extensive coverage of US banking reports and supports the frequent movement of extremely high volumes of complex data, creating and validating the XML transmission for reports filing to US Federal Reserve, Treasury, FFIEC and other agencies.  There is an array of management tools to deliver both the regulatory reporting and the workflow and management approval and attestation processes required.

Lombard Risk AgileREPORTER US reporting:

  • Support banking reports for Federal Reserve, Treasury, FFIEC and other agencies
  • Ongoing maintenance & implementation ensuring you are always up to date
  • Delivers embedded regulatory reporting production process, reducing risk
  • Ensures management has a comprehensive view of reporting status, trends & change analysis
  • Delivers single solution for end-to-end reporting with streamlined workflow & exception management

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