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Proposed Rules Financial Institutions

Ankura

Crafting Effective Public Comments: How and Why You Should Participate in the Rulemaking Process

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When regulators propose a new rule, financial institutions can often find themselves pushed into a reactionary position, left to deal with consequences that rule makers may not have foreseen. Once a rule hits the books, legal...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

Haynes Boone

Financial Services Regulatory Roundup | August 2025

Haynes Boone on

TABLE OF CONTENTS: • President Trump Signs GENIUS Act Into Law • Joint Statement on Crypto Risk Management • Federal Agencies Propose Rescission of the 2023 Community Reinvestment Act Final Rule • FDIC Seeks Input...more

A&O Shearman

EC consults on the treatment of equity exposures under legislative programmes

A&O Shearman on

The European Commission has published a targeted consultation, accompanied by a press release, on a draft communication regarding the prudential treatment of equity investments by banks under legislative programmes in Article...more

Sheppard Mullin Richter & Hampton LLP

In a Surprising Switch, CFPB Now Seeks to Rewrite Open Banking Rule

On July 29, the U.S. District Court for the Eastern District of Kentucky granted the CFPB’s request to stay litigation challenging its open banking rule. The rule (previously discussed here) aimed to establish industry-wide...more

Ballard Spahr LLP

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

Ballard Spahr LLP on

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

Mayer Brown

US FDIC Requests Comment on Industrial Loan Company Framework

Mayer Brown on

On July 15, 2025, the Federal Deposit Insurance Corporation (“FDIC”) requested comment on its framework for reviewing applications for deposit insurance from industrial loan companies and industrial banks (collectively,...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

Cadwalader, Wickersham & Taft LLP

Global Moves, Digital Shifts, July 2025 - Fed, FDIC and OCC Issue Proposed Rulemaking to Rescind 2023 CRA Rule

Last week, the Federal Deposit Insurance Corporation (“FDIC), Federal Reserve Board (“FRB”), and the Office of the Comptroller of the Currency (“OCC”) (collectively, “the Agencies”)  issued a proposed rulemaking to both...more

Sheppard Mullin Richter & Hampton LLP

CFPB Withdraws Rule to Eliminate State Enforcement Notification Requirements

On July 21, the CFPB withdrew its plan to repeal rules that provide procedures for state officials to notify the Bureau before initiating enforcement actions under the Consumer Financial Protection Act (CFPA). The CFPB cited...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Delays Effective Date of Investment Adviser Rule and Intends to Revisit the SEC Customer Identification Program Rule for...

In September 2024, FinCEN issued the Investment Adviser Rule, which aims to “address ongoing illicit finance risks, threats, and vulnerabilities posed by criminals and foreign adversaries that exploit the U.S. financial...more

Mayer Brown

Federal Reserve Proposes Changes to Rating System for Large Financial Institutions

Mayer Brown on

On July 10, 2025, the Board of Governors of the Federal Reserve System (“Board”) proposed changes to its supervisory rating systems for large financial institutions (“LFIs”) and supervised insurance organizations (the...more

Davis Wright Tremaine LLP

Rethinking Bank Leverage and Capital Requirements in 2025

On July 10, 2025, the federal banking agencies published a proposed rule to change the enhanced supplementary leverage ratio (eSLR) for U.S. global systemically important bank holding companies (GSIBs) and their subsidiary...more

Orrick, Herrington & Sutcliffe LLP

FDIC withdraws proposed rule on industrial banks and loan companies

On July 15, the FDIC Board withdrew a proposed rule concerning the oversight of parent companies of industrial banks and industrial loan companies. The withdrawal means the FDIC no longer intends to issue a final rule on...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

Orrick, Herrington & Sutcliffe LLP

FDIC submits changes to bank establishment and relocation rules

On July 15, the FDIC Board approved a notice of proposed rulemaking to streamline processes related to the establishment and relocation of domestic branches and offices. The FDIC’s stated its objective is to reduce 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

King & Spalding

CMS Escalates Aggressive Rates Cut in Home Health Prospective Payment System Proposed Rule for CY 2026

King & Spalding on

On June 30, 2025, CMS issued its annual Home Health Prospective Payment System Proposed Rule for Calendar Year (CY) 2026 (the Proposed Rule). The Proposed Rule continues the agency’s policy of using provisions of the...more

A&O Shearman

EBA consults on draft guidelines on application of definition of default and applying credit conversion factors under CRR

A&O Shearman on

The European Banking Authority (EBA) has published two consultation papers under the Capital Requirements Regulation (CRR), as amended by the revised Capital Requirements Regulation (CRR III). The first consultation paper...more

Orrick, Herrington & Sutcliffe LLP

Prudential regulators issue RFC on Call Report changes

On July 10, the OCC, the Fed, and the FDIC (the agencies) published a joint notice in the Federal Register for public comment on Call Report forms applicable to U.S. bank holding companies identified as global systemically...more

Ballard Spahr LLP

Budget bill does not include Senate proposal to delay Section 1071 for ten years, but Trump Administration again promises changes

Ballard Spahr LLP on

The huge budget bill signed by President Trump on July 4 does not include a proposal from Senate Banking, Housing and Urban Affairs Committee Republicans to delay implementation of the Section 1071 rule for ten years, but the...more

Cooley LLP

CFPB Announces Plan to Review Offenses Carrying Criminal Penalties

Cooley LLP on

On June 27, the Consumer Financial Protection Bureau (CFPB) issued a policy statement, “Guidance on Referrals for Potential Criminal Enforcement,” which outlines its plan to address criminal regulatory offenses within its...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

A&O Shearman

PRA consults on proposed reforms to credit union investment rules

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The Prudential Regulation Authority (PRA) has published consultation paper CP13/25 proposing amendments to the credit union investment rules to permit investments in credit union service organisations (CUSOs). The proposals...more

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