In a recent client publication, Shearman & Sterling summarizes the Federal Reserve's recent proposal to implement heightened prudential requirements for the largest US financial institutions. The proposed rules were required by Dodd-Frank and would require institutions to design and implement compliance, recordkeeping and reporting procedures for the new standards. As Shearman & Sterling notes, covered institutions may take some solace, though perhaps not much, in the fact that many of the proposed requirements are consistent with emerging international standards for supervision of large financial companies. The publication summarizes the new proposal, identifies the portions applicable to various types of covered financial institutions and outlines the various requirements applicable to each type. Comments on the proposal are due by March 31, 2012.