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Enforcement to Endorsement: Digital Asset Executive Order and SAB 121 Rescission

President Trump signed an executive order ("EO") titled "Strengthening American Leadership in Digital Financial Technology" that signals a radical shift in the federal government's posture towards digital assets and the...more

Federal Banking Agencies Propose Long-Term Debt Requirements for Large Banks

In Short: The Situation: The Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation (collectively, the "Agencies") have proposed rules...more

CFPB Guidance Puts Creditors on Notice About AI-Involved Adverse Actions

Recent Consumer Financial Protection Bureau ("CFPB") guidance reiterates that creditors must provide consumers with accurate and individualized explanations for adverse actions—a task made more difficult by the complexity of...more

FDIC Proposes Toughening CIDI Resolution Plan Rules

In Short - The Situation: The Federal Deposit Insurance Corporation ("FDIC") has proposed significant amendments (the "Proposal") to its rule requiring covered insured depository institutions ("CIDIs") to prepare and file...more

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