Key takeaways

• Legislation with bipartisan support is pending in both houses of the U.S. Congress to revise the $50 billion asset threshold in the Dodd-Frank Act that triggers application of enhanced prudential standards for U.S. and foreign bank holding companies.
• Although broader legislative changes to the Dodd-Frank Act appear unlikely at this juncture, revisions to the Dodd-Frank Act’s $50 billion threshold appear to have positive momentum both in Congress and with the administration.  In fact, the Trump administration has repeatedly signaled support for revising the threshold, while leaving the details of how to do so to Congress. 
• If the Dodd-Frank threshold is revised, the federal banking agencies separately may feel compelled to revisit a range of other regulations and guidance that, even though not required by statute, have used the $50 billion asset line to trigger more stringent standards.