Introduction - On February 25, 2026, the Office of the Comptroller of the Currency (the “OCC”) issued a Notice of Proposed Rulemaking (the “NPRM”) to implement the Guiding and Establishing National Innovation for U.S....more
2/27/2026
/ Banking Sector ,
Comment Period ,
Digital Assets ,
FinTech ,
New Legislation ,
OCC ,
Payment Systems ,
Proposed Rules ,
Regulatory Oversight ,
Regulatory Reform ,
Rulemaking Process ,
Stablecoins
In a February 3, 2026 speech to the Investment Company Institute’s Winter Board Meeting, Brian Daly, Director of the SEC’s Division of Investment Management, requested industry comment on how the use of artificial...more
2/18/2026
/ Artificial Intelligence ,
Comment Period ,
Disclosure Requirements ,
Emerging Technologies ,
Financial Services Industry ,
FinTech ,
Innovation ,
Innovative Technology ,
Investment Adviser ,
Investment Funds ,
Investment Management ,
Regulatory Oversight ,
Regulatory Reform ,
Rulemaking Process ,
Securities and Exchange Commission (SEC)
In the recently grand tradition of Maryland making waves in the consumer financial services space, the Mayor and City Council of Baltimore filed suit against Dave, Inc., a fintech that uses a “proprietary AI underwriting...more
2/18/2026
/ Artificial Intelligence ,
Consumer Financial Products ,
Consumer Lenders ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Fees ,
FinTech ,
Overdraft Fees ,
Payday Loans ,
State and Local Government ,
Underwriting ,
Unfair or Deceptive Trade Practices
I. Introduction -
U.S. banks are increasingly turning to significant risk transfers (SRTs) to manage credit risk and optimize regulatory capital. SRTs are transactions that satisfy the definition and operational criteria...more
2/13/2026
/ Banking Sector ,
Banks ,
Capital Requirements ,
Contract Terms ,
Credit Default Swaps ,
FDIC ,
Financial Institutions ,
Financial Services Industry ,
Regulatory Requirements ,
Risk Management ,
Securitization
On January 28, 2026, the SEC’s Divisions of Corporation Finance, Investment Management, and Trading and Markets issued a joint statement addressing “tokenized securities.”...more
2/13/2026
/ Blockchain ,
Cryptoassets ,
Digital Assets ,
Digital Securities ,
Distributed Ledger Technology (DLT) ,
FinTech ,
New Guidance ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Security-Based Swaps ,
Tokenization
I. Executive Summary - On December 19, 2025, the CFTC’s Market Participants Division (“MPD”) issued Staff No-Action Letter No. 25-51, establishing a three-month pilot program under which certain energy commodity end-user...more
1/7/2026
/ CFTC ,
Derivatives ,
Dodd-Frank ,
Energy Market ,
Energy Sector ,
No-Action Letters ,
Pilot Programs ,
Regulatory Reform ,
Reporting Requirements ,
Rulemaking Process ,
Swap Dealers
I. Executive Summary -
On December 8, 2025, the staff of the U.S. Commodity Futures Trading Commission (“CFTC”) launched a “digital assets pilot program” (the “Digital Assets Pilot Program”) providing greater certainty to...more
12/26/2025
/ CFTC ,
Commodity Exchange Act (CEA) ,
Cryptoassets ,
Cryptocurrency ,
Derivatives ,
Derivatives Clearing Organizations ,
Digital Assets ,
Futures Commission Merchants (FCMs) ,
New Guidance ,
No-Action Letters ,
Popular ,
Regulatory Reform ,
Stablecoins ,
Tokenization
On December 11, 2025, the staff of the SEC’s Division of Trading and Markets issued a no-action letter (the “DTCC No-Action Letter”) stating that it would not recommend enforcement action against The Depository Trust Company...more
On December 9, 2025, the Market Participants Division, the Division of Clearing and Risk, and the Division of Market Oversight (the “Divisions”) of the U.S. Commodity Futures Trading Commission (“CFTC”) issued Staff Letter...more
On December 16, 2025, the FDIC issued a notice of proposed rulemaking to implement the application and approval requirements under the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act”)...more
12/22/2025
/ Banking Sector ,
BSA/AML ,
Comment Period ,
Digital Assets ,
FDIC ,
Financial Services Industry ,
FinTech ,
Notice of Proposed Rulemaking (NOPR) ,
Payment Systems ,
Rulemaking Process ,
Stablecoins
On December 12, 2025, the Office of the Comptroller of the Currency (“OCC”) granted the conditional approval of five national trust bank charter applications involving crypto-focused institutions. The approvals include two de...more