News & Analysis as of

Financial Institutions Federal Reserve Regulatory Oversight

Orrick, Herrington & Sutcliffe LLP

Fed withdraws its notice on supervising “novel activities”

On August 15, the Fed announced it withdrew its bank supervision program related to the Fed’s initiatives on “novel activities.” The Fed will return to monitoring banks’ novel activities through the normal supervisory...more

Cadwalader, Wickersham & Taft LLP

New Lessons in Regulation, August 2025 - FRB Rescinds Novel Activities Supervision Program and Vice Chair Bowman Speaks on...

Last week, (almost two years to the day of when it was issued), the Federal Reserve Board (“FRB”) rescinded SR Letter 23-7 regarding the creation of the Novel Activities Supervision Program. The FRB stated that supervision of...more

Troutman Pepper Locke

The Federal Reserve’s Shift in Supervision Strategy for Novel Activities

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On August 15, the Federal Reserve Board announced a significant shift in its approach to supervising novel activities within banking organizations. The Board decided to sunset its Novel Activities Supervision Program, which...more

Orrick, Herrington & Sutcliffe LLP

Senators pen letter to bank regulators on matters requiring attention

On August 6, the U.S. Senate Banking Committee sent a letter to the Fed’s Vice Chair for Supervision, Michelle Bowman, as well as Comptroller Jonathan Gould, and the FDIC’s Acting Chairman Travis Hill, urging them to address...more

Bradley Arant Boult Cummings LLP

State Laws Show Uniformity Is Key To Truly Fair Bank Access

Over the past few years, one of the more noteworthy types of new financial services rules at the state level has been the so-called fair access to banking law. Concerns about ideological debanking have gained political...more

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

Orrick, Herrington & Sutcliffe LLP

Fed and FDIC release the public sections of 64 banks’ living wills

On August 5, the Fed and FDIC released the public sections of 2025 resolution plans for the eight largest and most complex domestic banking organizations and 56 foreign banking organizations. The plans, as required by the...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - August 2025 - GENIUS Act Establishes Legal Framework for Payment Stablecoins

The President signed into law the Guiding and Establishing National Innovation for U.S. Stablecoins of 2025’or ‘‘GENIUS Act of 2025’” (the Act) on July 18, 2025. The new law establishes a basis for regulators to permit a...more

Nutter McClennen & Fish LLP

The GENIUS Act is Signed into Law: What Banks Need to Know about Payment Stablecoins

On July 18, 2025, President Trump signed into law the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act”), after it passed both the U.S. Senate by a vote of 68-30 and the U.S. House in a...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

Vedder Price

Jonathan Gould Confirmed as Comptroller of the Currency

Vedder Price on

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

Skadden, Arps, Slate, Meagher & Flom LLP

The Capital Ratio Podcast | Entering the US Banking Market

When crafting an entry into the U.S. markets, U.K. and European financial institutions need to carefully plan an appropriate strategy. Sebastian Barling, host of “The Capital Ratio” is joined by financial institutions...more

Ballard Spahr LLP

Fed to end use of reputational risk in examination programs

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The Federal Reserve Board has announced that it will eliminate reputational risk as a component of examination programs in its supervision of banks. ...more

Orrick, Herrington & Sutcliffe LLP

District court receives amici request to participate in oral argument

On June 13, the U.S. District Court for the District of North Dakota received a motion from two amici curiae seeking leave to participate in oral arguments scheduled for July 23 on the parties’ cross motions for summary...more

GeoDataVision

Why Do Federal Bank Regulators Create a Commercial Monopoly on Key Benchmark Data?

GeoDataVision on

Ever since the 1995 CRA rule was published bank regulators have mandated certain “community” and “market” benchmarks as the basis for rating bank performance under the CRA regulations. Most of that data is in the public...more

Orrick, Herrington & Sutcliffe LLP

Fed appoints Michael Horowitz to serve as OIG for Fed and CFPB

On June 6, the Fed appointed Michael E. Horowitz to lead the OIG for the Fed effective June 30. By statute, the Fed’s OIG also serves as Inspector General for the CFPB. The OIG’s mandate includes making recommendations to...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

Mintz

Federal Reserve Disbands Climate-Focused Internal Groups

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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

Patomak Global Partners

Fed Withdrawal of Guidance Marks Milestone for Banks’ Future Crypto Activity

The federal banking agencies have withdrawn previously issued guidance related to banks’ crypto activities, marking a shift in regulatory posture toward digital asset engagement. On April 25, the Federal Reserve Board...more

Secretariat

Guardians of Finance Integrity, How the NY Fed’s Oversight in Iraq and Libya Could Hold a Blueprint for Post-Conflict...

Secretariat on

The Federal Reserve Bank of New York (FRBNY) has cemented its role as a global financial watchdog, using its influence to safeguard the integrity of the U.S. dollar and the broader international financial system. Recent...more

Orrick, Herrington & Sutcliffe LLP

Regulators withdraw crypto guidance, plan further clarity for banks

On April 24, the FDIC and the Fed announced they have retracted two joint statements concerning banking organizations’ activities related to crypto-assets. According to the agencies, this move aims to clarify that banking...more

Paul Hastings LLP

Support for Stablecoin Legislation and Leadership Confirmations

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While the House and Senate were out of session for the last two weeks, federal financial regulators and legislators took a wide range of actions impacting the future of digital asset policy. Senate Banking Chair Tim Scott...more

Alston & Bird

Federal Banking Agencies Announce Intent to Rescind 2023 Community Reinvestment Act Final Rule and Return to Prior Framework

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What Happened? The Federal Deposit Insurance Corporation (“FDIC”), Board of Governors of the Federal Reserve System (“Federal Reserve”) and the Office of the Comptroller of the Currency (“OCC”), (collectively, “federal...more

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