These rules have been reshaped to counteract the risks to the U.S. financial system revealed by the crisis and should be implemented consistently across all firms that engage in similar activities.
Similarly, other enhanced prudential standards required by the Dodd-Frank Act – including stress testing requirements, risk management requirements, single counterparty credit limits, and early remediation requirements – should be applied to the U.S. operations of large foreign banks in a manner consistent with the Board’s domestic proposal.25 Third, there should be liquidity standards for large U.S. operations of foreign banks.