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Paul Hastings LLP

Executive Order Calls for Crackdown on Politicized Debanking

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On August 7, President Donald Trump signed the “Guaranteeing Fair Banking for All Americans” executive order (EO) directing federal banking regulators to investigate financial institutions that have restricted access to...more

Paul Hastings LLP

Preparing Banks for the Next Round of Challenges While the Sun Is Still Shining

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Fifteen years ago, in the shadow of the 2008 financial crisis, Congress adopted the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), the most significant change to financial regulation since the...more

DLA Piper

“Fair Banking” Executive Order Targets Politicized Debanking and Reputational Risk

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On August 7, 2025, President Donald Trump issued an Executive Order entitled “Guaranteeing Fair Banking for all Americans” (EO). The EO broadly prohibits banks and other financial institutions from engaging in “politicized or...more

Moore & Van Allen PLLC

Federal Reserve Board Hosts Capital Conference to Further Capital Reform Efforts

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On July 22, 2025, the Board of Governors of the Federal Reserve System (Board) hosted a first-of-its-kind industry conference designed to solicit public input on reform of the U.S. capital framework for financial...more

Orrick, Herrington & Sutcliffe LLP

Fed officials emphasize need for progress on financial inclusion

Recently, two members of the Fed, the Vice Chair for Supervision, Michelle Bowman, and Governor Michael Barr, both spoke on the ongoing challenges and opportunities in advancing financial inclusion across the U.S. Both...more

Orrick, Herrington & Sutcliffe LLP

White House Working Group on Digital Asset Markets releases report

On July 30, the president’s Working Group on Digital Asset Markets released a report setting out a coordinated federal approach to digital asset regulation. The report called for agencies to provide clearer guidance and...more

Ballard Spahr LLP

FDIC proposes to replace Supervision Appeals Review Committee with an independent office

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The FDIC is proposing to replace its Supervision Appeals Review Committee (SARC) with an independent, standalone office, known as the Office of Supervisory Appeals (OSA). Under the proposal, the OSA would be the final level...more

Davis Wright Tremaine LLP

Federal Banking Regulators Propose to Formally Flip Position on Biden-Era CRA Rules

In an expected move, the federal banking regulators issued a notice of proposed rulemaking (NPRM) to rescind Biden-era amendments to the 2023 regulations implementing the Community Reinvestment Act (CRA). The NPRM, issued by...more

Paul Hastings LLP

Banking Regulators Clarify Crypto Custody Expectations, Congress Advances Landmark Digital Asset Legislation and Senate Releases...

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In a pivotal week for digital asset policy, federal banking regulators issued long-awaited guidance outlining risk-management expectations for crypto-asset safekeeping activities. The OCC, Federal Reserve and FDIC released a...more

Smith Anderson

Feds' Shift On Reputational Risk Raises Questions For Banks

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In a significant shift, each of the country's three federal bank regulatory agencies have announced they will no longer consider reputational risk as a stand-alone supervisory category. Originally published in Law360 -...more

Morrison & Foerster LLP

The GENIUS Act: A New Federal Regulatory Framework for Payment Stablecoins

On July 18, 2025, President Trump signed into law S. 1582, the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act” or the “Act”). The Act covers payment stablecoins[1]—a relatively new form...more

Vedder Price

OCC Ends Use of Disparate Impact in Fair Lending Supervision

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The Office of the Comptroller of the Currency (“OCC”) has formally revised its fair lending examination procedures, announcing in Bulletin 2025-16, issued on July 14, 2025, that it has eliminated all references to disparate...more

Davis Wright Tremaine LLP

Federal Reserve Board Proposes Revisions to Large Financial Institution Rating System

On July 15, 2025, the Federal Reserve Board released a proposed rule to revise the Large Financial Institution rating system or "LFI Framework." The proposal would change how the Fed evaluates the financial and managerial...more

Vedder Price

Jonathan Gould Confirmed as Comptroller of the Currency

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On Thursday, July 10, 2025, the U.S. Senate confirmed Jonathan Gould to serve as the next Comptroller of the Currency in a 50–45 vote. Gould will succeed Acting Comptroller Rodney Hood, who offered his congratulations and...more

Orrick, Herrington & Sutcliffe LLP

Prudential regulators propose rule on bank capital requirements

On June 27, the OCC, the Fed, and the FDIC issued a notice of proposed rulemaking to revise the enhanced supplementary leverage ratio standards for U.S. global systemically important banks (GSIBs) and their subsidiaries. The...more

Orrick, Herrington & Sutcliffe LLP

Congress reduces CFPB’s budget request cap following passage of reconciliation bill

On July 3, the House of Representatives passed H.R.1, the “One Big Beautiful Bill Act” to reduce the cap on amounts the CFPB can request from the Fed to fund its operations from 12 percent to 6.5 percent of the Fed’s total...more

Mayer Brown Free Writings + Perspectives

US Banking Regulators Propose Enhanced Supplementary Leverage Ratio Reform

Last week, the US federal banking regulators proposed changes to the enhanced supplementary leverage ratio (“eSLR”) requirement for US global systemically important bank holding companies (“US GSIBs”) (the “Proposal”)....more

Orrick, Herrington & Sutcliffe LLP

Sen. Warren pens letter against removing the enhanced supplementary leverage ratio for banks

On June 23, the Ranking Member of the U.S. Senate Committee on Banking, Housing, and Urban Affairs, Sen. Elizabeth Warren (D-MA), penned a letter raising concerns over reports that the Fed, the FDIC, and the OCC intended to...more

Orrick, Herrington & Sutcliffe LLP

Fed announces that examination programs will no longer consider reputational risk

On June 23, the Fed announced it will no longer include reputational risk as a component of its examination programs in its supervision of banks. This move will align the Fed with the OCC, which made a similar announcement in...more

Perkins Coie

GENIUS Act Passes US Senate in Significant Step Towards Regulatory Clarity for Stablecoins

Perkins Coie on

The U.S. Senate passed the Guiding and Establishing National Innovation for U.S. Stablecoins Act or GENIUS Act (S.1582) (the Act) in a 68-30 bipartisan vote on June 17, 2025. The GENIUS Act would provide a clear regulatory...more

Sheppard Mullin Richter & Hampton LLP

Federal Reserve Board Removes Reputational Risk from Examination Ratings

On June 23, the Federal Reserve Board announced that reputational risk will no longer be a component of its bank-examination program. The same day, the Board released a revised edition of its Guidelines for Rating Risk...more

Cadwalader, Wickersham & Taft LLP

The Fine Print, June 2026 - Federal Banking Agencies Issue Proposed Rulemaking To Amend eSLR

This week, the Federal Reserve Board (“FRB") and the Office of the Comptroller of the Currency (“OCC”) issued a notice of proposed rulemaking (“NPR") to amend the Enhanced Supplementary Leverage Ratio (“eSLR”). At the time of...more

Kohrman Jackson & Krantz LLP

Federal Reserve Signals Shift Toward Pragmatic Banking Regulation

With a focus on pragmatic and risk-based oversight, new leadership at the Federal Reserve signals a shift in the regulatory landscape for U.S. banks. Earlier this month, the Senate confirmed Federal Reserve Governor Michelle...more

Cadwalader, Wickersham & Taft LLP

Heating Up, June 2025 - Vice Chair Bowman Gives Outline of Her Agenda Following Senate Confirmation

Last Friday, following her confirmation by the Senate as Federal Reserve Board Vice Chair of Supervision, Michelle Bowman laid out some of her priorities in a speech entitled “Taking a Fresh Look at Supervision and...more

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – June 2025 # 2

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week....more

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