The Committee is concerned by the E.U.’s Proposal to require third-country banking groups to establish an EU-based intermediate holding company (“IHC”) for subsidiaries located in the EU. In this letter, the Committee recommends that the European Commission withdraw its Proposal.

The Committee further recommends that the Federal Reserve reconsider its IHC requirement for foreign banking organizations. In particular, the Federal Reserve should evaluate whether its IHC requirement could increase risk to the U.S. financial system by reducing the ability of international banking organizations to respond to a crisis. The letter can be found here.