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US Banking Regulators Propose Enhanced Supplementary Leverage Ratio Reform

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

OCC Withdraws Climate Risk Management Principles

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

Congress Moves Forward on Stablecoin Legislation: The US Senate Banking Committee Approves the GENIUS Act

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

CFPB Finalizes Long-Awaited Rule to Accelerate Open Banking Development; Immediately Sued

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

FDIC Proposes New Recordkeeping Requirements for Custodial Accounts

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

Regulatory Redux: FDIC Proposes Brokered Deposit Revisions

On July 30, 2024, the FDIC proposed revisions to the restrictions on brokered deposits. The revisions would undo many of the key elements of the 2020 revisions, and would dramatically expand the number of deposit brokers and...more

US Banking Regulators Finalize Nonbank Lending Reporting Requirements

On May 22, 2024, the US federal banking regulators finalized a new set of reporting requirements for bank loans and commitments to fund finance facilities, private credit lenders, and other nonbank financial entities.This...more

Cybersecurity Regulations on the March

Join us on the latest episode of Financial Services Focus as Justin Herring, Jeff Taft and Ana Bruder discuss key cyber threats facing the financial services industry, including third-party risks, sophisticated ransomware,...more

A Look Ahead

Join us for the first episode of Mayer Brown’s Financial Services Focus series. Financial Services Focus will provide updates on the key legal issues affecting financial products across legal disciplines. This podcast series...more

CFPB Finalizes Rule Significantly Restricting Credit Card Late Fees—Litigation Immediately Follows

On March 5, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) issued a Final Rule that would significantly restrict late fees that consumer credit card issuers may charge from $30 or $41, in most cases, to a mere...more

What to Expect in Banking in 2024

The end of 2023 saw a barrage of major proposals and other actions by US banking regulators. Many of these are contentious issues that have divided regulators and generated significant public controversy. Final proposals of...more

Time Warp? Proposed Basel Endgame Reporting Requirements Released Before Final Rule

On January 26, 2024, the US federal banking regulators announced proposed reporting changes to implement the Basel III Endgame requirements. This may come as a surprise to the many banking organizations and others, who only...more

Private Credit Reporting Requirements Proposed by US Banking Regulators

On December 27, 2023, the US federal banking regulators proposed a new set of reporting requirements for bank loans and commitments to private credit lenders and intermediaries....more

A Road Not Taken: Where the US Capital Proposal Differs From Basel

On July 27, 2023, US federal banking regulators issued proposals to (i) significantly revise the riskbased regulatory capital requirements for certain midsize and larger US banking organizations (the “Capital Proposal”) and...more

Overhaul of Regulatory Capital Requirements Proposed by US Banking Regulators

On July 27, 2023, US federal banking regulators issued proposals to (i) significantly revise the riskbased regulatory capital requirements for certain midsize and larger US banking organizations (the “Capital Proposal”), and...more

Connecticut and Florida Join the Fray, Enact Commercial Finance Disclosure Laws

Following closely on the heels of a Georgia law enacted in May, Connecticut and Florida have become the latest states to enact laws requiring providers of small business financing to provide disclosures to recipients—and in...more

The Suspense Is Over – NYDFS Adopts Final Commercial Financing Disclosure Rules, Announces Effective Date, and Provides New...

Small business financers and brokers (“providers”) active in New York are officially on notice to finalize their preparations to comply with New York’s Commercial Finance Disclosure Law (“CFDL”) by August 1, 2023, the new...more

CFPB Preliminarily Determines State Commercial Financing Disclosure Laws Not Preempted by Truth in Lending Act

Small business lenders hoping for federal intervention will be disappointed to learn that the Consumer Financial Protection Bureau (CFPB) has reached a preliminary determination that New York’s new commercial financing...more

Utah Enacts Commercial Financing Disclosure Law with a Registration Obligation

Utah has followed California and New York by enacting its own Truth in Lending-like commercial financing disclosure law, but with an additional twist—Utah’s new law has a registration requirement. On March 24, Utah Governor...more

NYDFS Issues Pre-Proposed Rules to Implement New Commercial Financing Disclosure Law

The New York Department of Financial Services (NYDFS) has issued “pre-proposed” rules under New York’s commercial financing disclosure law that was enacted at the end of 2020.  The pre-proposed rules are 45 pages in length...more

Congress Prepares to Invalidate OCC’s True Lender Rule

On Thursday (March 26, 2021), Senator Chris Van Hollen (D-MD) introduced a Congressional Review Act (CRA) resolution of disapproval to invalidate the Office of the Comptroller of the Currency’s (OCC) true lender rule....more

NY Expands Coverage of Recently Enacted Commercial Financing Disclosure Law

As expected, New York has broadened the reach of its new commercial financing disclosure law less than two months after its enactment. S.B. 5470, as previously reported by Mayer Brown, imposed a range of Truth in Lending-like...more

Legal Update: NY Enacts TILA-Like Disclosure Law for Business Loans and Purchases of Receivables (Factors, MCA Providers,...

In late December 2020, New York Governor Andrew Cuomo signed S.B. 5470 into law, which will impose a range of Truth in Lending Act-like disclosure requirements on providers of commercial financing in amounts of $500,000 or...more

Structured Finance Bulletin - Winter 2020

The implications of the 2020 election for structured finance are coming into focus. Informed by our discussions in Washington, we can anticipate the likely direction of federal policy over the next two years that will impact...more

US Agencies Proposed Revisions to Volcker Rule Covered Funds Provisions

On January 30, 2020, the Board of Governors of the Federal Reserve System (“FRB”), the Federal Deposit Insurance Corporation (“FDIC”), the Office of the Comptroller of the Currency (“OCC”), the Securities and Exchange...more

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