As such, our rules subject a large foreign bank to the same capital and liquidity requirements as domestic bank holding companies by requiring the foreign bank to hold its U.S. subsidiaries through a U.S. intermediate holding company (IHC) and imposing capital and liquidity requirements to the IHC.
At the same time, we have adjusted our approach for the U.S. branches of a foreign bank with a large U.S. presence in recognition that branches are subject to a narrower set of permissible activities and operate as a direct extension of the parent bank.