On June 2nd the IIF submitted letters on the topic of intermediate holding companies for foreign banking organisations to the European Commission, the US Federal Reserve and the Financial Stability Board. The letters refer to the proposed Intermediate Parent Undertaking requirements in the EU, the existing Intermediate Holding Company requirements in the US and signs of a growing trend towards regulatory fragmentation in financial markets.

These letters raise important issues about requirements for intermediate holding companies (IHCs) including the constraints to efficient funding and capital flows (with detrimental implications for financial stability) and the potentially negative economic impacts of IHCs. Each of the letters calls on these authorities to enter a dialogue aimed at addressing these issues and ensuring that IHC requirements are respectful of, and consistent with, the agreed global resolution framework.'