News & Analysis as of

Risk Management Proposed Rules

Nutter McClennen & Fish LLP

Nutter Bank Report: July 2025

In the wake of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act), the federal banking agencies have issued joint guidance to provide clarity on supervisory expectations for banks that...more

Polsinelli

Virtual Oversight, Real Impacts: “Incident-To” and Beyond in CMS’s CY 2026 PFS Proposed Rule

Polsinelli on

Key Takeaways - CMS proposes to significantly expand the use of virtual direct supervision for incident-to services, removing prior limitations based on Professional Component (PC)/Technical Component (TC) indicators and...more

Cooley LLP

COSO Drops Proposed Corporate Governance Framework (For Now)

Cooley LLP on

Last week, COSO withdrew its public exposure draft for a corporate governance framework just a month after it was proposed. This was a set of FAQs about it that was posted when the proposal first was made....more

Jackson Lewis P.C.

OSHA Proposes Dozens of Deregulatory Rules: How They’ll Impact Multiple Industries

Jackson Lewis P.C. on

The Occupational Safety and Health Administration (OSHA) has published over two dozen proposed rules in the Federal Register on July 1, 2025, marking a sweeping regulatory initiative that impacts multiple industries. Although...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

Morgan Lewis

OSHA’s Aggressive Deregulatory Efforts Begin

Morgan Lewis on

The Occupational Safety and Health Administration (OSHA) has begun what the US Department of Labor describes as “aggressive deregulatory efforts” to “put American workers and job creators first.” In response to President...more

Jones Day

Reform of the EU Securitisation Framework—Part 1: STS Label Extended to Unfunded Credit Protection

Jones Day on

In January 2019, the EU introduced its current regulatory framework for securitisations, seeking to improve transparency, robustness, and market confidence following the global financial crisis. Market participants have...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

Ropes & Gray LLP

ESMA Proposes Significant Reforms to UCITS Eligible Assets Rules

Ropes & Gray LLP on

ESMA has recently recommended notable amendments to the UCITS Eligible Assets Directive, which sets the standards for permissible investments by UCITS funds across Europe. These reforms could redefine permissible investment...more

Polsinelli

CMS Proposes New Mandatory, Two-Sided Risk Model for Heart Failure and Low Back Pain

Polsinelli on

Key Takeaways - CMS has proposed a mandatory two-sided risk model for specialists treating heart failure and low back pain in outpatient settings....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

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

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

Bergeson & Campbell, P.C.

APHIS Seeks Comment on Draft Environmental Documents for Deregulation of American Chestnut Developed Using Genetic Engineering 

On June 6, 2025, the U.S. Department of Agriculture’s (USDA) Animal and Plant Health Inspection Service (APHIS) announced that it has prepared a revised draft environmental impact statement (EIS) and revised draft plant pest...more

Bergeson & Campbell, P.C.

FDA Begins Public Comment Period on Method for Ranking Chemicals in Food for Post-Market Assessments 

The U.S. Food and Drug Administration (FDA) announced on June 18, 2025, the release of its proposed method for ranking chemicals in the food supply. According to the document, the systematic post-market assessment of food...more

A&O Shearman

PSR consults on the revocation of SD4

A&O Shearman on

The UK Payment Systems Regulator (PSR) has published consultation paper CP25/2 alongside a new webpage, proposing the revocation of Specific Direction 4 (SD4) and its amendment, SD4a. SD4, introduced following the PSR's 2016...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

BCLP

The Long-Awaited FCA Paper on Non-financial Misconduct – Was It Worth the Wait?

BCLP on

On 2 July 2025, the FCA published a further consultation paper on “tackling non-financial misconduct in financial services”. The industry has been eagerly awaiting publication of this paper, in the hope that it will address...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

ArentFox Schiff

FDA Unveils a Tool for Prioritizing Food Chemicals for Post-Market Assessment

ArentFox Schiff on

On June 18, the US Food and Drug Administration (FDA) released for public comment a proposed method for ranking chemicals present in the food supply to determine which should be prioritized for post-market safety assessments....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

Jackson Lewis P.C.

Cal/OSHA’s Significant Revisions to Proposed Workplace Violence Regulation Would Create More Obligations for More Employers

Jackson Lewis P.C. on

The California Division of Occupational Safety and Health, better known as Cal/OSHA, has issued significant revisions to its proposed workplace violence regulation. The proposal provides needed clarity for employers but also...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

Maynard Nexsen

COSO and NACD Publish a Proposed Corporate Governance Framework

Maynard Nexsen on

On May 27, 2025, the Committee of Sponsoring Organizations of the Treadway Commission (“COSO”), in collaboration with the National Association of Corporate Directors (“NACD”), released and is inviting public comment on an...more

K&L Gates LLP

United States: The Great SEC Spring Clean Up–14 Proposals Wiped Away

K&L Gates LLP on

Spring is a time of renewal, and the US Securities and Exchange Commission (SEC)–under its new chairman, Paul Atkins–has shown that. On 12 June 2025, the SEC withdrew 14 proposed rules impacting funds and asset managers,...more

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