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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Reg Reform Update – Financial Regulations To Be Clarified or Repealed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

Senate Moves To End "Operation Choke Point" De-Banking With New Bill—But More Protections Are Needed

Following a key hearing in February, Senate Banking Committee Chairman Tim Scott (R-SC) is seeking to protect financial freedom with the introduction of the Financial Integrity and Regulation Management (FIRM) Act. The...more

OCC Rescinds Required Supervisory "Non-Objection" Preclearance for Permissible Crypto-Related Activities

The OCC has reiterated that certain crypto-related activities—crypto-asset custody, distributed ledger, and stablecoin activities—previously determined to be permissible remain so. The OCC has also rescinded a Biden-era...more

New Administration Outlook: FDIC Moves To Rescind Key, Controversial Proposals

The FDIC has signaled the reversal of key, controversial proposals from 2024. In doing so, it has provided welcome clarity on important areas that implicate banks of various sizes and charter types, allowing banks to focus on...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: 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

New Administration Outlook: Trump Administration Transforms U.S. Policy on Digital Assets

The Trump Administration has embarked on a fundamental shift on how the United States approaches digital assets—in marked contrast with the Biden Administration's policies—likely changing the prospects of the crypto market in...more

Tools To Limit the Administrative State – The Revival and Enhancement of Executive Orders

Efforts by the Executive Branch to shape and control regulatory output is nothing new. Beginning with the Nixon Administration, several administrations have issued Executive Orders (EOs) to limit or otherwise influence how...more

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