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OCC Reverts to Prior Merger Rules

The Office of the Comptroller of the Currency (OCC) has issued an interim final rule that restores streamlined and expedited regulatory procedures to review applications under the Bank Merger Act for business combinations...more

Reg Reform Update – Financial Regulations To Be Clarified or Repealed

While tariff policy has captured headlines, four recent regulatory reform policy developments are nevertheless significant for the financial services industry. These developments are tied to increasing presidential control...more

Reintroduction of Bill To Speed Up BHCA and HOLA Applications

The Trump Administration has made clear that it intends to lessen the barriers to bank merger and acquisition activity. As we previously noted, the FDIC has moved to lower some of the impediments to mergers under its 2024...more

New Administration Outlook: Trump's Executive Order on Independent Agencies—and Asserting the Unitary Executive (Part 1)

Despite the tone and tint of recent headlines, President Trump's February 18, 2025, "Ensuring Accountability for All Agencies" Executive Order (the "Accountability EO") appears to be the latest in a long line of efforts to...more

New Administration Outlook: Game Changer—Newly Revived Executive Order 13892 Expands Protections for Regulated Parties, For Now

The recent confirmation of Russ Vought as director of the Office of Management and Budget (OMB) is expected to kickstart the Administration's centralized approach to reforming the administrative state. The recently revived...more

New Administration Outlook: An Opening for a National Payments/Fintech Charter – and a Pathway to Financial Modernization?

Recent announcements by Trump Media and Technology Group (TMTG) and X might signal that financial modernization may have finally reached a tipping point. With the right regulatory environment, fintechs and other new market...more

New Administration Outlook: SEC Announces Creation of Crypto Task Force

On January 21, 2025, Acting SEC Chairman Mark Uyeda announced the creation of a crypto Task Force dedicated to developing a "comprehensive and clear regulatory framework for crypto assets." Acting Chairman Uyeda tasked...more

New Administration Outlook: The Executive Branch, Schedule F, and Other Tools To Cabin Administrative Discretion

We have previously analyzed the recent history of Executive Orders ("EOs") controlling the issuance and content of regulations. As we saw on Inauguration Day 2025, and continue to see, the second Trump Administration is...more

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