On November 21, 2025, the Structured Finance Association, on behalf of the risk transfer market, received no-action relief on the issue of registration as a commodity pool operator (“CPO”) from the staff of the Division of...more
On October 9, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), jointly with the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the...more
11/12/2025
/ AML/CFT ,
Bank Secrecy Act ,
BSA/AML ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Regulatory Reform ,
Regulatory Requirements ,
Reporting Requirements ,
Suspicious Activity Reports (SARs)
On October 21, 2025, Governor Christopher J. Waller of the Board of Governors of the Federal Reserve System (the “Federal Reserve”) delivered opening remarks at the inaugural Payments Innovation Conference (the...more
In July, Congress passed, and President Donald Trump signed, the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act”). The GENIUS Act was a watershed moment in the history of...more
10/23/2025
/ Anti-Money Laundering ,
Banks ,
Cryptocurrency ,
Digital Assets ,
Financial Services Industry ,
FinTech ,
New Legislation ,
Proposed Rules ,
Regulatory Requirements ,
Rulemaking Process ,
Stablecoins ,
The GENIUS Act ,
U.S. Treasury
On October 7, 2025, the Federal Deposit Insurance Corporation (“FDIC”) and the Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a Notice of Proposed Rulemaking regarding Prohibition on Use...more
10/13/2025
/ Banking Sector ,
Executive Orders ,
FDIC ,
Federal Register ,
Financial Services Industry ,
OCC ,
Proposed Rules ,
Regulatory Agencies ,
Regulatory Oversight ,
Regulatory Reform ,
Risk Management
On September 30, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued a request for information (“AML Survey”) on the costs that nonbank financial institutions (“NBFIs”) incur to comply with anti-money laundering...more
Recently, Illinois amended several provisions of its banking laws (HB3467). These changes were supported by the Illinois banking community and are intended to harmonize Illinois Banking Act and Illinois Savings Bank Act....more
9/23/2025
/ Banking Sector ,
Banks ,
Corporate Governance ,
Financial Institutions ,
Illinois ,
Insured Depository Institutions ,
National Bank Act ,
New Amendments ,
New Legislation ,
Regulatory Reform ,
Shareholder Meetings
On August 18, 2025, Illinois enacted Senate Bill 1797, the Digital Assets and Consumer Protection Act (the “Act”), establishing a regulatory framework designed to enhance customer protections for digital asset activities and...more
9/4/2025
/ Blockchain ,
Consumer Protection Laws ,
Cryptocurrency ,
Digital Assets ,
Disclosure Requirements ,
Financial Services Industry ,
Illinois ,
New Legislation ,
Regulatory Oversight ,
Regulatory Requirements ,
State and Local Government
On August 7, 2025, President Donald Trump issued an Executive Order entitled “Guaranteeing Fair Banking for All Americans” (the “Order”). The Order announces the Administration’s plan to address the exclusion of certain...more
Effective August 1, 2025, Louisiana will subject revenue-based financing transactions to new disclosure requirements, joining the still-growing ranks of states passing commercial finance disclosure laws in recent years. But...more
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
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
Today, President Donald Trump signs into law the Guiding and Establishing National Innovation for US Stablecoins Act of 2025 (the “GENIUS Act”), establishing the first federal regulatory framework for stablecoins in the...more
7/18/2025
/ Anti-Money Laundering ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Protection Laws ,
Cryptocurrency ,
Digital Assets ,
Federal Reserve ,
Financial Regulatory Reform ,
New Legislation ,
OCC ,
Stablecoins ,
Trump Administration
Companies that service or collect commercial debt are reminded that new practice requirements are taking effect in California starting July 1, 2025. As Mayer Brown reported when California Senate Bill 1286 was enacted in...more
Last week, the US federal banking regulators proposed changes to the enhanced supplementary leverage ratio (“eSLR”) requirement for US global systemically important bank holding companies (“US GSIBs”) (the “Proposal”)....more
7/1/2025
/ Banking Regulators ,
Banking Sector ,
Basel III ,
Capital Markets ,
Capital Requirements ,
Comment Period ,
FDIC ,
Federal Reserve ,
Financial Regulatory Reform ,
OCC ,
Proposed Rules ,
Regulatory Reform
On March 28, 2025, the Internal Revenue Service (“IRS”)’s criminal investigative arm, IRS Criminal Investigation (“IRS-CI”), announced that it would be implementing a new program called CI-FIRST (Feedback in Response to...more
On March 31, 2025, the Office of the Comptroller of the Currency withdrew its participation in the interagency principles for climate-related financial risk management for large financial institutions (the “Climate...more
On March 28, 2025, the Federal Deposit Insurance Corporation (FDIC) issued guidance on state nonmember bank and state savings association participation in certain cryptocurrency activities (“FIL-7-2025”). ...more
4/9/2025
/ Banks ,
Cryptocurrency ,
Digital Assets ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
Investment Products ,
OCC ,
Regulatory Reform ,
Regulatory Requirements ,
Stablecoins
The Fifth Circuit vacated the Federal Trade Commission’s (“FTC”) Combating Auto Retail Scams Trade Regulation Rule (“CARS Rule”) on January 27, 2025, determining that the FTC failed to follow its own procedural requirements...more
On March 13, 2025, the US Senate Banking Committee passed the Guiding and Establishing National Innovation for US Stablecoins Act of 2025 or “GENIUS Act,” out of committee by a vote of 18-6....more
3/20/2025
/ Bankruptcy Code ,
Cryptocurrency ,
Digital Assets ,
Digital Currency ,
Federal Reserve ,
Financial Regulatory Reform ,
FinTech ,
OCC ,
Regulatory Requirements ,
Stablecoins ,
U.S. Treasury
On March 7, 2025, the Office of the Comptroller of the Currency (OCC) issued guidance on national bank and federal savings association participation in certain cryptocurrency activities (“IL 1183”). This guidance is the...more
Since President Donald Trump took office last month, his actions have marked a significant shift in federal policy, paving the way for the creation of a new regulatory framework impacting banks, financial services, and the...more
AT A GLANCE -
The Federal Reserve and FDIC have withdrawn from the Network for Greening the Financial System due to concerns that its activities exceeded the Federal Reserve's and the FDIC's statutory mandates—and amid...more
On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) finalized a rulemaking on Personal Financial Data Rights (the “Final Rule”). The Final Rule is intended to accelerate a shift towards open banking in the...more
11/6/2024
/ Banks ,
Consumer Data Requests ,
Consumer Financial Protection Bureau (CFPB) ,
Data Management ,
Dodd-Frank ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Open Banking ,
Popular
On September 17, 2024, the Federal Deposit Insurance Corporation (FDIC) proposed extensive new recordkeeping requirements and other compliance obligations (the “Proposal” ) for certain types of deposit accounts frequently...more