The FDIC sought public comment on a proposed rule to amend its international banking regulations (Part 347) consistent with section 939A (section 939A) of the Dodd- Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) and the FDIC’s authority under section 5(c) of the Federal Deposit Insurance Act (FDI Act). Section 939A directs each federal agency to review and modify regulations that reference credit ratings. The rule would amend the provisions of subparts A and B of part 347 that reference credit ratings.  Subpart A, which sets forth the FDIC’s requirements for insured state nonmember banks that operate foreign branches, would be amended to replace references to credit ratings in the definition of ‘‘investment grade’’ with a standard of creditworthiness that has been adopted in other federal regulations that conform with section 939A. Subpart B would be amended to revise the FDIC’s asset pledge requirement for insured U.S. branches of foreign banks. The eligibility criteria for the types of assets that foreign banks may pledge would be amended by replacing the references to credit ratings with the revised definition of investment grade.  The rule would apply this investment grade standard to each type of pledgeable asset, establish a liquidity requirement for such assets, and subject them to a fair value discount. The proposed rule would also introduce cash as a new asset type that foreign banks may pledge under subpart B and create a separate asset category expressly for debt securities issued by government sponsored enterprises.