News & Analysis as of

Regulatory Oversight Risk Management

Orrick, Herrington & Sutcliffe LLP

FDIC releases February 2025 CRA evaluations

On May 5, the FDIC released a list of state non-member banks evaluated for compliance with the CRA during February 2025. Under the CRA, the FDIC assesses how effectively banks meet the credit needs of their entire community,...more

Orrick, Herrington & Sutcliffe LLP

OCC requests information on banks’ digitalization efforts

On May 5, the OCC released a request for information (RFI) seeking public comment on community banks’ efforts towards digitalization. The OCC stated this RFI will enhance its supervisory activities. The OCC aims to understand...more

McGuireWoods LLP

Banks May Provide Cryptocurrency Transaction and Custody Services, but OCC Has Yet to Provide Clear Compliance Requirements

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On May 7, 2025, the Office of the Comptroller of the Currency (“OCC”) issued a follow up to its July 2020 Interpretative Letter 1170, which allowed national banks to provide cryptocurrency custody services to their customers....more

Sheppard Mullin Richter & Hampton LLP

OCC’s Hood Emphasized AI Oversight and Inclusion in Financial Services

On April 29, Acting Comptroller of the Currency Rodney Hood delivered pre-recorded remarks at the National Fair Housing Alliance’s Responsible AI Symposium.  In his speech, Hood reiterated the OCC’s commitment to deploying AI...more

A&O Shearman

ECON draft report on safeguarding and promoting financial stability amid economic uncertainties

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The European Parliament's Committee on Economic and Monetary Affairs (ECON) has published a draft report on safeguarding and promoting financial stability amid economic uncertainties. The draft report emphasises the...more

Goodwin

Fighting Market Abuse in Crypto-Assets: ESMA Guidelines Under MiCA

Goodwin on

Published on April 29, 2025, the ESMA final report (ESMA75-453128700-1408) outlines the guidelines (Guidelines) for competent national authorities (NCAs) to prevent and detect market abuse in the context of the Markets in...more

Ropes & Gray LLP

CIPAC Disbandment and CISA 2015 Reauthorization: Recent Developments in the U.S. Cybersecurity Landscape

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On March 7, 2025, the Department of Homeland Security (“DHS,” “the agency”) disbanded the Critical Infrastructure Partnership Advisory Council (“CIPAC,” “the Council”), originally established in 2006 to facilitate...more

Baker Botts L.L.P.

AI Governance in the Agent Era

Baker Botts L.L.P. on

“AI governance” is a rapidly developing field of research that focuses on the risks and controls related to AI platforms. Recently, a team of researchers from the Institute for AI Policy and Strategy has proposed a framework...more

Carlton Fields

Contingent Deferred Annuities: Time for Renewal?

Carlton Fields on

Contingent deferred annuities (CDAs) represent an interesting approach to securing lifetime income but have struggled for recognition in the marketplace since their introduction more than a decade ago. Recent developments,...more

A&O Shearman

FSB Chair Letter to G20 Finance Ministers

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The Financial Stability Board (FSB) has published a letter, along with a press release and webpage, from its Chair, Klaas Knot, to G20 finance ministers and central bank governors ahead of their meeting on 23-24 April. The...more

A&O Shearman

PRA consults on restating MiFID Organisational Regulation

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The UK Prudential Regulation Authority (PRA) has published its consultation paper (CP9/25) on the Markets in Financial Instruments Directive Organisational Regulation (MiFID Org Reg). The PRA proposes to restate the current...more

Carlton Fields

NAIC Big Data Working Group Continues Building a Regulatory Structure

Carlton Fields on

During the NAIC Spring National Meeting, the Big Data and Artificial Intelligence (H) Working Group reviewed its blueprint to build an overarching regulatory edifice to oversee insurers’ use of artificial intelligence...more

Orrick, Herrington & Sutcliffe LLP

Senate committee seeks information on DOGE’s impact at FDIC

On April 24, four members of the U.S. Senate Committee on Banking, Housing, and Urban Affairs sent a letter to the FDIC requesting information regarding DOGE’s involvement at the FDIC. The senators are seeking information...more

White & Case LLP

NERC Tees Up Plan to Assess Grid Risks Associated with Data Centers

White & Case LLP on

The North American Electric Reliability Corporation (NERC) outlined forthcoming activities to identify and address the potential impacts to reliability as a result of the rapid expansion of data centers and other large...more

Ballard Spahr LLP

OCC, FDIC eliminating ‘reputational risk’ from supervision, examinations

Ballard Spahr LLP on

The OCC has removed “reputational risk” from its handbooks and guidance and the FDIC is moving to do the same. ...more

A&O Shearman

FSB publishes finalised format for FIRE framework

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The Financial Stability Board (FSB) has published its finalised Format for Incident Reporting Exchange (FIRE), together with a press release and updated webpage. FIRE provides a standardised format for financial institutions...more

Cadwalader, Wickersham & Taft LLP

European Supervisory Authorities Make Recommendations for the EU Securitisation Market

Background Article 44 of the EU’s Securitisation Regulation (“SECR”) requires the Joint Committee of the European Supervisory Authorities (“ESAs”) to produce a report every three years on: (a) the implementation of...more

Stinson LLP

CFPB and OCC Signal Strategic Shifts in Supervision and Enforcement

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In April 2025, both the Consumer Financial Protection Bureau (CFPB) and the Office of the Comptroller of the Currency (OCC) announced significant changes to their supervisory and enforcement approaches, signaling a shift in...more

A&O Shearman

FCA findings on multi-firm review of trading apps

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The UK Financial Conduct Authority (FCA) has published a webpage summarising the findings from its multi-firm review of trading apps, together with a press release. The FCA notes that this is a growing sector allowing more...more

Conyers

Regulatory Update: Cayman Islands VASP Licensing Regime Now in Effect

Conyers on

The Cayman Islands Government has taken a significant step in the regulation of virtual asset service providers (VASPs) with the commencement of the licensing regime under the Virtual Asset (Service Providers) Act (as...more

Davis Wright Tremaine LLP

CFTC Divisions Issue Staff Advisory on Referrals to Division of Enforcement

On April 17, 2025, the Market Participants Division, the Division of Clearing and Risk, and the Division of Market Oversight (collectively, the "Operating Divisions") of the CFTC, along with the Division of Enforcement...more

Wiley Rein LLP

[Podcast] Contracting for Success: Key Legal Considerations When Segmenting Pharmacy Benefit Programs

Wiley Rein LLP on

In this episode of The Wiley Contracting Chronicles, co-hosts Jordan Ross and Brooke DeLoatch take a deeper dive into program segmentation within pharmacy benefit programs. After outlining the concept in their previous...more

Conn Maciel Carey LLP

NFPA 660: A New Scheme for Managing Combustible Dust

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The National Fire Protection Association (NFPA) has changed the way industries manage combustible dust and particulate solid hazards by replacing six separate combustible dust standards with one consolidated and streamlined...more

Pillsbury Winthrop Shaw Pittman LLP

California SB 813 Proposes Landmark Safe Harbor for AI Development Through Certification

With SB 813, California introduces a first-in-the-nation framework that reduces regulatory uncertainty and encourages responsible AI innovation. In addition to fostering public-private cooperation over top-down mandates, the...more

A&O Shearman

PRA Dear CFO letter: prudential expectations on significant risk transfer financing

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The Prudential Regulation Authority (PRA) has published a Dear CFO letter outlining its prudential expectations regarding practices related to illiquid and structured financing portfolios. The PRA focuses on significant risk...more

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