US branches of non-US banks: Access to US COVID-19 facilities and programs

As during the 2008 global financial crisis, the US financial regulators and Congress are taking emergency action to ensure the availability of liquidity and credit to the US financial system in response to the COVID-19 pandemic. US branches and agencies of non-US banks (US Branches) are in many regards treated as US financial institutions for the purpose of these actions. US Branches may be positioned to realize benefits through participation in US COVID-19 programs and facilities but also will need to carefully navigate the COVID-19-related compliance requirements of the quickly changing US financial regulatory landscape.

This alert provides an overview of how the rapidly evolving US COVID-19 regulatory response applies to US Branches in respect of the availability of emergency funding and liquidity and compliance with new and changing regulatory measures. The alert discusses the following in turn:

• Emergency lending facilities, outlining the availability of emergency funding sources for or through US Branches to support US businesses, US households and markets,
• Emergency investment programs, outlining programs in which US Branches may be eligible to participate as lenders or liquidity providers to US businesses, and
• Emergency regulatory compliance measures, outlining the new compliance requirements and expectations resulting from key measures implemented by US federal and state authorities to facilitate the flow of funding and liquidity and otherwise provide relief to US households, US businesses and the US economy.

Our team will provide periodic updates and insights as the COVID-19 pandemic and the US response continues to develop. Please refer to our COVID-19 Regulatory and Legislative Dashboard to help track the fast-changing regulatory actions, facilities, programs and laws.

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