News & Analysis as of

Federal Reserve Banking Sector Risk Management

Latham & Watkins LLP

Banking Agencies Issue Joint Statement on Risk-Management Considerations for Cryptoasset Safekeeping

Latham & Watkins LLP on

Banking organizations safekeeping digital assets for customers must do so in a safe and sound manner and in compliance with applicable laws and regulations....more

Sheppard Mullin Richter & Hampton LLP

Federal Banking Regulators Issue Joint Guidance on Crypto-Asset Safekeeping

On July 14, the OCC, Federal Reserve, and FDIC announced the release of a joint statement clarifying how existing laws and regulations apply to crypto-asset safekeeping services offered by banking organizations. The statement...more

Orrick, Herrington & Sutcliffe LLP

Prudential regulators release statement on cryptocurrency safekeeping

On July 14, the OCC, the Fed, and the FDIC issued a joint statement addressing how existing laws, regulations and governing principles apply to banks which provide or are considering providing safekeeping for...more

Troutman Pepper Locke

Federal Agencies Release Guidance on Crypto-Asset Safekeeping for Banks

Troutman Pepper Locke on

On July 14, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (the Board), and the Federal Deposit Insurance Corporation (FDIC) jointly issued a statement addressing the...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

Cadwalader, Wickersham & Taft LLP

Midyear Momentum, July 2025 - Federal Reserve Releases Results of Stress Tests

On June 27, the Federal Reserve Board issued the aggregate and individual results of the supervisory stress test (also known as the Dodd-Frank Act Stress Test or DFAST, as these tests are required by Section 165 of the...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

Fed releases annual stress test results for 2025

On June 27, the Fed released the results of its annual supervisory stress test, evaluating how large banks would perform under hypothetical adverse economic conditions. The Fed conducts stress tests annually as part of its...more

Loeb & Loeb LLP

Banking Agencies Propose Long-Sought Changes to Capital Rules for the Largest U.S. Banks

Loeb & Loeb LLP on

The Federal Reserve, alongside the Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC), released their highly anticipated Notice of Proposed Rulemaking to overhaul the Enhanced...more

Nutter McClennen & Fish LLP

Nutter Bank Report: June 2025

The Federal Reserve has announced that the agency will no longer assess reputational risk when examining banks’ risk management processes. According to the June 23 announcement, the Federal Reserve has already begun reviewing...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

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

Orrick, Herrington & Sutcliffe LLP

Fed Vice Chair for Supervision discusses using “pragmatism” in regulating banks safely

On June 6, the Fed’s Vice Chair for Supervision, Michelle Bowman, outlined her approach to enhance banking supervision and regulation during prepared remarks. In her remarks, Bowman emphasized using “pragmatism” to identify...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

Orrick, Herrington & Sutcliffe LLP

Fed releases its Senior Financial Officer Survey results for March 2025

On May 30, the Fed released its results of its Senior Financial Officer Survey summarizing responses from bank officers regarding their reserve balance management strategies and practices. The survey concluded on March 31 and...more

Mintz

Federal Reserve Disbands Climate-Focused Internal Groups

Mintz on

It has been reported that the Federal Reserve has disbanded certain internal groups that were intended to develop “institutional capacity and knowledge” with respect to climate risk. Specifically, among the groups that have...more

Orrick, Herrington & Sutcliffe LLP

GAO Report Reveals How Financial Institutions (And Their Regulators) Are Using AI

Curious about how financial institutions, their service providers, and their federal regulators are using and overseeing machine learning and other AI tools? A new GAO report published on May 19th (the “Report”) provides a...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Climate Change Financial Risk Act of 2025: U.S. Senate Legislation Introduced Directing the Federal Reserve to Address Financial...

United States Senator Brian Schatz (Hawaii) has introduced legislation titled: Climate Change Financial Risk Act of 2025 (“Act”). The Act directs the United States Federal Reserve to conduct stress tests on large...more

Cadwalader, Wickersham & Taft LLP

May Market Moves, May 2025 - Modifications to the Capital Plan Rule and Stress Capital Buffer Requirement – Notice of Proposed...

The Federal Reserve Board has requested comment on a proposal designed to reduce the volatility of the capital requirements stemming from its annual stress tests. The proposal would achieve this primarily by averaging the...more

Sheppard Mullin Richter & Hampton LLP

Kansas City Federal Reserve Bank Explores Regulatory Risks in Gaming Ecosystems

On April 9, the Federal Reserve Bank of Kansas City published a research briefing examining how video game platforms are reshaping the digital payments landscape. As in-game purchases and platform-based transactions grow in...more

Orrick, Herrington & Sutcliffe LLP

Fed’s Barr speaks on fintech-bank partnerships, generative AI

On April 4, Fed Governor Michael S. Barr spoke at the Federal Reserve Bank of San Francisco about how banks and fintech companies can work together to accelerate the adoption of generative AI in financial services....more

Ballard Spahr LLP

Republicans ask federal banking agencies to withdraw rules, guidance

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Republicans on the House Financial Services Committee have sent letters to financial regulators asking them to rescind a variety of measures the regulators issued during the Biden Administration....more

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