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Comment Period Financial Institutions

A&O Shearman

EBA consults on draft RTS and guidelines for third country branches under CRD IV

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The European Banking Authority (EBA) has published three consultation papers under Directive 2013/36 (CRD IV), as amended by Directive 2024/169 (CRD VI), relating to the regulatory requirements for third country branches...more

A&O Shearman

EBA consults on amending RTS on own funds and eligible liabilities under CRR

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The European Banking Authority (EBA) has published a consultation paper proposing amendments to Commission Delegated Regulation (EU) No 241/2014 on the timing for the application for prior permission to reduce own funds and...more

Troutman Pepper Locke

Federal Banking Agencies Propose Rescission of 2023 CRA Final Rule and Reinstatement of 1995 CRA Regulations

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On July 16, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the federal banking agencies) jointly published a proposed rule...more

Orrick, Herrington & Sutcliffe LLP

Fed requests comments on its Large Financial Institution rating system

On July 15, the Fed published a notice and request for comment in the Federal Register on revisions to its Large Financial Institution (LFI) rating system and the Insurance Supervisory Framework. The rating system governs...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Banking Regulators Propose Changes to the Enhanced Supplementary Leverage Ratio for US GSIBs

On June 27, 2025, the Federal Reserve approved a proposal to recalibrate a key capital requirement applicable to the largest U.S. banking organizations (known as global systemically important banks (GSIBs)). - The proposal...more

Ballard Spahr LLP

CFPB proposes to rescind rule requiring nonbanks to register certain agency enforcement and court orders

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The CFPB is proposing to rescind its rule that requires certain nonbank entities to register covered agency enforcement and court orders....more

Orrick, Herrington & Sutcliffe LLP

CFPB proposes to rescind its nonbank registry rule

On May 14, the CFPB published a Federal Register notice withdrawing its proposed rule requiring nonbanks to report the existence of an order and file annual compliance reports where such nonbanks were subject to certain final...more

A&O Shearman

SRB consultation on operational guidance on resolvability testing for banks

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The Single Resolution Board (SRB) has opened a consultation on its operational guidance on resolvability testing for banks under the SRB's remit. It aims to ensure that European banks are regularly testing their capabilities...more

A&O Shearman

Basel Committee on Banking Supervision consults on amendments to principles for the management of credit risk

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The Basel Committee on Banking Supervision (Basel Committee) published a consultative document on updating the principles for the management of credit risk. The principles, first issued in October 2000, provide guidelines for...more

WilmerHale

CFPB Proposes Significant Expansion in Scope of EFTA and Regulation E

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On January 10, 2025, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed interpretive rule that would expand the Bureau’s consumer protection authority under the Electronic Fund Transfer Act (EFTA) and...more

Orrick, Herrington & Sutcliffe LLP

CFPB issues new proposal to ban certain financial contract terms

On January 13, the CFPB proposed a new rule to ban large banks and consumer finance companies from using certain contractual provisions in agreements with consumers under Regulation AA. The CFPB’s proposal warns against the...more

Orrick, Herrington & Sutcliffe LLP

CFPB seeks comments on proposed interpretive rule expanding the application of the EFTA to a wide range of digital assets

On January 10, the CFPB proposed an interpretive rule that could significantly broaden the scope of the EFTA to encompass a broad range of digital assets, including—if they meet certain requirements — cryptocurrency accounts,...more

A&O Shearman

UK Financial Conduct Authority consults on a new product information framework for consumer composite investments

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The U.K. Financial Conduct Authority has published a consultation on a new product information framework for Consumer Composite Investments. The regime will apply in respect of a CCI which is or may be distributed to a retail...more

A&O Shearman

European Securities and Markets Authority consults on the internal control framework for certain market agencies

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The European Securities and Markets Authority has published a consultation on draft guidelines on internal controls for benchmark administrators, credit rating agencies, and market transparency infrastructures (which include...more

A&O Shearman

Mansion House: UK Financial Conduct Authority and Financial Ombudsman Service Call for Input on Modernizing the Redress System

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The U.K. Financial Conduct Authority and the Financial Ombudsman Service have launched a joint call for input on modernizing the redress system. The two main concerns of the FCA and the FOS are mass redress events and FCA-FOS...more

A&O Shearman

UK Financial Conduct Authority Publishes Discussion Paper on Improving the UK Transaction Reporting Regime

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The U.K. Financial Conduct Authority has issued a discussion paper on potential options for improving the U.K. transaction reporting regime. The FCA has two primary objectives: to improve the usefulness of transaction...more

Ballard Spahr LLP

California’s DFPI seeks comments on additional products and services to be registered under the CCFPL

Ballard Spahr LLP on

In the wake of the Office of Administrative Law’s approval of its registration and reporting requirements for providers of income-based advances, private postsecondary education financing, debt settlement services, and...more

Nutter McClennen & Fish LLP

Nutter Bank Report: November 2024

The CFPB has adopted a final rule to extend its oversight to the largest nonbank providers of digital consumer payment applications, including those that enable transfers from deposit accounts held at banks and other insured...more

Orrick, Herrington & Sutcliffe LLP

FDIC extends comment period for its custodial account NPRM

On November 18, the FDIC announced it would extend the comment period for its NPRM on recordkeeping for custodial deposit accounts by 45 days. The initial comment period, which began on October 2 was set to close on December...more

Troutman Pepper Locke

FDIC Extends Comment Period for Proposed Rule on Recordkeeping for Third-Party Deposits

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In a previous post, we discussed the Federal Deposit Insurance Corporation’s (FDIC) notice of proposed rulemaking aimed at enhancing recordkeeping for bank deposits received from fintech and other third-party, non-bank...more

Ballard Spahr LLP

FinCEN Issues Proposed Reporting Form for Residential Real Estate Deals

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As we previously blogged, the Financial Crimes Enforcement Center (“FinCEN”) published Anti-Money Laundering Regulations for Residential Real Estate Transfers (“Final Rule”) regarding residential real estate. The Final Rule,...more

A&O Shearman

European Securities and Markets Authority Consults on Amendments to Markets in Financial Instruments Directive Research Regime

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The European Securities and Markets Authority has published a consultation on amendments to the research provisions in the revised Markets in Financial Instruments Directive following changes introduced by the Listing Act....more

A&O Shearman

Financial Action Taskforce Publishes Consultation on Changes to AML/CFT and Financial Inclusion Standards

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The Financial Action Taskforce has published a consultation paper on revisions to its anti-money laundering and counterterrorism financing standards relating to financial inclusion. The consultation is part of FATF's program...more

Shipkevich PLLC

California DFPI Seeks Greater Oversight Over Additional Consumer Financial Services: Seeks Comments on Who Should Be Regulated...

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The ink is barely dry on the California Department of Financial Protection and Innovation’s (“DFPI” or the “Department”) newly approved regulation package PRO 01-21, and DFPI has already begun to take steps to implement...more

Troutman Pepper Locke

FDIC Extends Comment Period for Proposed Changes to Brokered Deposit Regulations

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Yesterday, the Federal Deposit Insurance Corporation (FDIC) announced an extension of the comment period for its notice of proposed rulemaking (NPR) aimed at revising the 2020 Brokered Deposit Rule. To ensure that all...more

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