Debevoise & Plimpton LLP partner and Banking Group Chair Satish M. Kini testified today on aspects of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) before the United States House of Representatives Committee on Financial Services’ Subcommittee on Financial Institutions and Consumer Credit.

As part of the hearing, titled “Examining the Designation and Regulation of Bank Holding Company SIFIs,” Mr. Kini:

• Discussed the Dodd-Frank Act’s $50 billion asset threshold for imposing enhanced prudential standards on bank holding companies and contrasted this approach with the indicator-based methodology adopted by the Basel Committee on Banking Supervision;
• Reviewed the enhanced prudential standards applied to bank holding companies at the $50 billion level under the Dodd-Frank Act and examined how that $50 billion asset threshold has been exported for use in an array of other contexts; and
• Offered thoughts on alternative approaches to the $50 billion threshold for Congress to consider.

Mr. Kini’s remarks drew on his over two decades of experience counseling financial services firms and banking organizations, including bank holding companies that are subject to enhanced prudential standards under section 165 of the Dodd-Frank Act. In his practice, he has represented bank and other financial services firms in a broad range of matters, including by participating in the policy making process.

Mr. Kini’s prepared remarks are available here in PDF format.

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