News & Analysis as of

Comment Period Financial Institutions

Davis Wright Tremaine LLP

FDIC Proposes Adding Flexibility to Official Sign and Advertising Requirements

On August 21, 2025, the Federal Deposit Insurance Corporation (FDIC) published a proposed rule with several key changes to its FDIC Official Sign and Advertising Rule, only two years after it adopted requirements that were...more

Orrick, Herrington & Sutcliffe LLP

OCC releases upcoming CRA evaluation schedule

On August 27, the OCC announced its schedule for CRA evaluations to be conducted in the fourth quarter of 2025 and the first quarter of 2026. The announcement encouraged public comment regarding CRA-related activities of the...more

Morgan Lewis

CFPB Invites Comment on Larger Participant Thresholds

Morgan Lewis on

The Consumer Financial Protection Bureau has issued advance notices of proposed rulemaking seeking public comment on whether to revise the thresholds that define “larger participants” in key consumer financial industries....more

Fisher Phillips

GLBA Set for Overhaul? 10 Questions That May Decide the Next Generation of Financial Privacy Law

Fisher Phillips on

Congress is asking the financial industry – and anyone else with a stake in consumer data – to weigh in on the future of the Gramm-Leach-Bliley Act (GLBA). On July 31, the US House Financial Services Committee leaders issued...more

Cozen O'Connor

AGs Clash over EPA Rollbacks, Net-Zero Standards

Cozen O'Connor on

Illinois AG Kwame Raoul co-led a coalition of 17 Democratic AGs, the city of Chicago, New York City, and the California Air Resources Board, in filing comments opposing the EPA’s proposal to repeal the 2024 Mercury and Air...more

A&O Shearman

Mansion House: Bank of England measures to maintain a fit for purpose resolution regime

A&O Shearman on

The Bank of England (BoE) has published a suite of publications in its capacity as the UK′s resolution authority, covering significant updates in relation to its approach to setting the minimum requirement for own funds and...more

A&O Shearman

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

A&O Shearman on

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

A&O Shearman on

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

Troutman Pepper Locke on

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

Ballard Spahr LLP on

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

A&O Shearman on

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

A&O Shearman on

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

WilmerHale on

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

A&O Shearman on

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

A&O Shearman on

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

A&O Shearman on

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

A&O Shearman on

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

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