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Amundsen Davis LLC

President Trump Takes Action to Ensure Fair Banking for All Americans

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On August 7, 2025, President Donald J. Trump signed an executive order titled “Guaranteeing Fair Banking for All Americans.” The order asserts that financial institutions have restricted the access of individuals and...more

A&O Shearman

BoE publishes fundamental rules for FMIs

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Following its November 2024 consultation, the Bank of England (BoE) has published final fundamental rules for financial market infrastructure firms (FMIs), a supervisory statement setting out how the BoE expects FMI to comply...more

Hogan Lovells

PEP talk: The UK FCA issues final guidance on the treatment of politically exposed persons

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The Financial Conduct Authority (“the FCA”) has published final guidance on the treatment of politically exposed persons (PEPs) for anti-money laundering purposes, which updates its Guidance issued in 2017 (“the 2017...more

Alston & Bird

FinCEN Delays Enforcement of Investment Adviser AML/CFT Rule

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Our Financial Services and Investment Funds Teams examine the delay by the Financial Crimes Enforcement Network (FinCEN) of the effective date for the Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)...more

Davis Wright Tremaine LLP

FDIC Rethinks Industrial Banks—Again

Industrial banks or industrial loan companies (ILCs)—FDIC-insured banks chartered by certain states, notably Utah—have long been a niche component of the U.S. financial system. These institutions may be owned by commercial...more

A&O Shearman

FSB chair letter on global outlook and priorities

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The Financial Stability Board (FSB) has published a letter from Andrew Bailey, Governor of the Bank of England, who was appointed chair of the FSB from 1 July. In the letter, the chair confirms his commitment to the FSB's...more

Smith Anderson

Feds' Shift On Reputational Risk Raises Questions For Banks

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In a significant shift, each of the country's three federal bank regulatory agencies have announced they will no longer consider reputational risk as a stand-alone supervisory category. Originally published in Law360 -...more

Orrick, Herrington & Sutcliffe LLP

OCC removes reference to disparate impact for examiners

On July 14, the OCC announced it has removed the references to disparate impact liability from the “Fair Lending” booklet of the Comptroller’s Handbook and has started removing references in other issuances. The OCC has also...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK’s Proposed New Captive Insurer Regime: Key Developments and Next Steps

What is new: The UK government has proposed a new regulatory framework for captive insurance companies, aiming to simplify regulations and enhance competitiveness in the financial services sector. Why it matters: 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

A&O Shearman

UK House of Lords committee launches call for evidence on growth of private markets

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The House of Lords Financial Services Regulation Committee (the Committee) has launched a call for evidence as part of its inquiry into the growth of private markets in the UK following the regulatory reforms introduced after...more

A&O Shearman

ESAs launch joint consultation on draft guidelines for ESG stress testing

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The European Supervisory Authorities (the European Banking Authority, European Insurance and Occupational Pensions Authority and the European Securities and Markets Authority) have launched a joint consultation on their joint...more

Bradley Arant Boult Cummings LLP

A New Rule Embraces Modernity in the Customer Identification Process

Financial institutions across the United States have grappled with compliance requirements under the Customer Identification Program (CIP) Rule for more than two decades. A new exemption, approved in June 2025, promises...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

Husch Blackwell LLP

New Exemption Order Creates More Flexibility and More Considerations with the Customer Identification Program Rule

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By an exemption order dated June 27, 2025, federal prudential regulators have given banks and credit unions some welcomed flexibility when collecting an individual’s or entity’s taxpayer identification number (TIN) during...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

Crunched Credit

You Know They Don’t Know What They’re Doing (Right?): Opportunities Abound

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With the zoftig and still mutitative Big, Beautiful Bill stumbling through an unseemly Congressional favor-trading lollapalooza, one is reminded of Ms. Pelosi’s famous quip, “We’ve got to pass this bill to know what’s in it.”...more

Cadwalader, Wickersham & Taft LLP

The Fine Print, June 2025 - The EU Makes Significant Changes to the Securitisation Regulations and Associated Prudential Rules

The EU has now published its final proposal here (the “SecReg Proposal”) for a regulation amending Regulation (EU) 2017/2402 (“SecReg”). This memo discusses the most notable changes from the 2017 version of SecReg, many of...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

Europe Proposes Relaxations for Liquidity Buffers Including Securitisation Positions

The European Commission has published a draft Regulation amending Delegated Regulation (EU) 2015/61 on the eligibility conditions for securitisations in the liquidity buffer of credit institutions (the “Draft”)....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

Cadwalader, Wickersham & Taft LLP

Final Proposal For Revisions To The EU Securitisation Regulation And The Capital Requirements Regulation

The EU has now published its final proposal here (the “SecReg Proposal”) for a regulation amending Regulation (EU) 2017/2402 (“SecReg”).  This memo discusses the most notable changes from the 2017 version of SecReg, many of...more

Dinsmore & Shohl LLP

Consumer Lending Compliance in Uncertain Times

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In recent months, virtually every regulated industry has witnessed announcements of significant regulatory changes, including the financial services sector....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

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