The Board's Regulation YY implements enhanced prudential standards for certain companies supervised by the Board, including foreign banking organizations. Among other requirements, the Board's Regulation YY requires a foreign banking organization with $50 billion or more in total U.S. non-branch assets as of June 30, 2015, to establish a U.S. intermediate holding company and transfer its ownership interest in the substantial majority of its U.S. subsidiaries to the U.S. intermediate holding company by July 1, 2016. The Board may permit variances from the requirements under Regulation YY and, in particular, may permit a foreign banking organization to hold its ownership interest in a U.S. subsidiary outside of its U.S. intermediate holding company or to use an alternative organizational structure. The Board has acted on requests from the following foreign banking organizations regarding certain of the requirements under Regulation YY:

October 19, 2016: Cooperatieve Rabobank U.A. (PDF)
General Counsel opinion letter to Ruurd Weulen Kranenberg, advising that the U.S. risk committee established by Cooperatieve Rabobank U.A., Utrecht, Netherlands, is consistent with the U.S. risk committee requirements under section 252.155 of Regulation YY.

October 19, 2016: Sumitomo Mitsui Financial Group, Inc. (PDF)
General Counsel opinion letter to Nobuyuki Kawabata, advising that the U.S. risk committee established by Sumitomo Mitsui Financial Group, Inc., Tokyo, Japan, is consistent with the U.S. risk committee requirements under section 252.155 of Regulation YY.

July 6, 2016: Societe Generale (PDF)
Approval of request for relief from the requirement to establish a U.S. intermediate holding company and comply with applicable requirements under Regulation YY by July 1, 2016.

July 6, 2016: Banco Bilbao Vizcaya Argentaria, S.A. (PDF)
Approval of request for a six-month extension of time, until January 1, 2017, to transfer five U.S. subsidiaries to its U.S. intermediate holding company.

February 18, 2016; Banco Santander S.A. (PDF)
Approval of request to exclude its ownership interest in certain U.S. subsidiaries from its U.S. intermediate holding company and denial of request to exclude its ownership interest in a U.S. subsidiary from its U.S. intermediate holding company.

February 18, 2016; Bank of Montreal (PDF)
Denial of request to exclude its ownership interest in a U.S. subsidiary from its U.S. intermediate holding company and approval of extension of time to transfer its ownership interest in the U.S. subsidiary to its U.S. intermediate holding company.

February 18, 2016; BNP Paribas (PDF)
Approval of request to exclude its ownership interest in certain U.S. subsidiaries from its U.S. intermediate holding company.

February 18, 2016; Credit Suisse AG (PDF)
Approval of request to exclude its ownership interest in certain U.S. subsidiaries from its U.S. intermediate holding company and denial of request to exclude its ownership interest in certain U.S. subsidiaries from its U.S. intermediate holding company.

February 18, 2016; Deutsche Bank AG (PDF)
Approval of request to exclude its ownership interest in certain U.S. subsidiaries from its U.S. intermediate holding company.

February 18, 2016; Royal Bank of Canada (PDF)
Denial of request to exclude its ownership interest in a U.S. subsidiary from its U.S. intermediate holding company.

February 18, 2016; Mizuho Financial Group Inc. (PDF)
Approval of request for a variance from certain U.S. risk committee requirements.

February 18, 2016; The Norinchukin Bank (PDF)
Approval of request for a variance from certain U.S. risk committee requirements.

December 11, 2014; The Royal Bank of Scotland plc (PDF)
Approval of request to extend asset measurement date for the initial applicability of the U.S. intermediate holding company requirement.

December 11, 2014; The Toronto-Dominion Bank (PDF)
Denial of request to exclude its ownership interest in a U.S. subsidiary from its U.S. intermediate holding company.

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Last Update: November 08, 2016