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Risk Management Regulatory Reform

Morgan Lewis - Tech & Sourcing

New York Seeks to RAISE the Bar on AI Regulation

New York state lawmakers on June 12, 2025 passed the Responsible AI Safety and Education Act (the RAISE Act), which aims to safeguard against artificial intelligence (AI)-driven disaster scenarios by focusing on the largest...more

A&O Shearman

ESAs launch joint consultation on draft guidelines for ESG stress testing

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The European Supervisory Authorities (the European Banking Authority, European Insurance and Occupational Pensions Authority and the European Securities and Markets Authority) have launched a joint consultation on their joint...more

Bradley Arant Boult Cummings LLP

A New Rule Embraces Modernity in the Customer Identification Process

Financial institutions across the United States have grappled with compliance requirements under the Customer Identification Program (CIP) Rule for more than two decades. A new exemption, approved in June 2025, promises...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Banking Regulators Propose Changes to the Enhanced Supplementary Leverage Ratio for US GSIBs

On June 27, 2025, the Federal Reserve approved a proposal to recalibrate a key capital requirement applicable to the largest U.S. banking organizations (known as global systemically important banks (GSIBs)). - The proposal...more

Jackson Lewis P.C.

Employers Won’t Face Double Damages from DOL Wage and Hour Division’s Administrative Proceedings

Jackson Lewis P.C. on

The U.S. Department of Labor’s Wage and Hour Division (WHD) has issued new internal guidance that significantly changes its approach to administrative settlements under the Fair Labor Standards Act (FLSA). In Field Assistance...more

Hogan Lovells

UK Mortgage Rule Review: FCA discussion paper on future of market seeks views on ‘trade-offs and risks’ that changing its rules...

Hogan Lovells on

Following the FCA’s May 2025 ‘first steps’ consultation on proposals to simplify its mortgage framework via a Mortgage Rule Review (MRR), it has now published a discussion paper on the future of the mortgage market. The...more

BakerHostetler

HHS Issues a Request for Information on Deregulation and Innovation: Considerations for Legal and Compliance Teams

BakerHostetler on

On May 14, 2025, the U.S. Department of Health and Human Services (HHS) issued its Request for Information (RFI) “Ensuring Lawful Regulation and Unleashing Innovation To Make American Healthy Again,” which HHS describes as...more

DLA Piper

Ireland: NIS2 Revamps Ireland’s Cybersecurity Landscape: Old Regulators, New Powers

DLA Piper on

The NIS2 Directive has significantly reshaped the cybersecurity landscape across the EU. Since the implementation deadline in October 2024, EU Member States have been working to incorporate new standards into their national...more

Husch Blackwell LLP

New Exemption Order Creates More Flexibility and More Considerations with the Customer Identification Program Rule

Husch Blackwell LLP on

By an exemption order dated June 27, 2025, federal prudential regulators have given banks and credit unions some welcomed flexibility when collecting an individual’s or entity’s taxpayer identification number (TIN) during...more

A&O Shearman

FCA publishes discussion paper on the future of the UK mortgage market

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The UK Financial Conduct Authority (FCA) has published discussion paper DP25/2 (DP) accompanied by an updated webpage and press release, on the future of the UK mortgage market, as part of its ongoing mortgage rule review....more

A&O Shearman

PSR consults on the revocation of SD4

A&O Shearman on

The UK Payment Systems Regulator (PSR) has published consultation paper CP25/2 alongside a new webpage, proposing the revocation of Specific Direction 4 (SD4) and its amendment, SD4a. SD4, introduced following the PSR's 2016...more

Stikeman Elliott LLP

CSA Release Three-Year Business Plan

Stikeman Elliott LLP on

On June 26, 2025, the Canadian Securities Administrators (“CSA”) published their 2025-2028 business plan (the “Plan”), which sets out the priorities that the CSA have committed to pursuing over the next three years....more

Orrick, Herrington & Sutcliffe LLP

Prudential regulators propose rule on bank capital requirements

On June 27, the OCC, the Fed, and the FDIC issued a notice of proposed rulemaking to revise the enhanced supplementary leverage ratio standards for U.S. global systemically important banks (GSIBs) and their subsidiaries. The...more

Morgan Lewis

CMS Is Getting WISeR About Medicare Waste—But At What Cost To Providers?

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The Centers for Medicare & Medicaid Services (CMS) recently announced the launch of the Wasteful and Inappropriate Services Reduction (WISeR) Model, a six-year model under the CMS Innovation Center aimed at reducing...more

Crunched Credit

You Know They Don’t Know What They’re Doing (Right?): Opportunities Abound

Crunched Credit on

With the zoftig and still mutitative Big, Beautiful Bill stumbling through an unseemly Congressional favor-trading lollapalooza, one is reminded of Ms. Pelosi’s famous quip, “We’ve got to pass this bill to know what’s in it.”...more

A&O Shearman

Regulatory monitoring - June 2025

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The EBA published a keynote speech delivered by its Chairperson, José Manuel Campa, at a high-level meeting for European supervisors in Ljubljana, Slovenia, on the importance of an efficient and effective financial services...more

Bergeson & Campbell, P.C.

EP Research Service Publishes Think Tank Briefing on EU Chemicals Strategy for Sustainability

On June 23, 2025, the European Parliamentary Research Service (EPRS) published a Think Tank briefing entitled “Targeted scrutiny of the EU chemicals strategy for sustainability.” According to EPRS, while the European...more

Shipman & Goodwin LLP

Connecticut’s Release-Based Cleanup Program: 10 Key Issues

Shipman & Goodwin LLP on

As Connecticut transitions away from the Transfer Act to a release-based cleanup program, developers, lenders, investors, owners, and tenants must quickly adapt to a significantly different regulatory environment. This...more

Akin Gump Strauss Hauer & Feld LLP

The EU Simplifies CBAM – What Are the Potential Implications?

The European Parliament and Council reached a provisional agreement (i.e., a post-consultation, non-binding political deal in relation to the final text of a legislative proposal) to streamline the European Union’s (EU)...more

Woodruff Sawyer

Expanding Retail Investor Access to Private Funds: A Spider-Man Problem

Woodruff Sawyer on

Private funds could be facing a Spider-Man problem. Let me explain. Because he was bitten by a radioactive spider, Spider-Man has superpowers. He can jump really high. He can shoot webs from his hands. When his...more

Bergeson & Campbell, P.C.

NIA Issues Position Paper on Divergent EU Approaches to Nano and Advanced Materials

On June 11, 2025, the Nanotechnology Industries Association (NIA) published a position paper entitled Bridging the Governance Gap: Divergent EU Approaches to Nano and Advanced Materials that highlights industry challenges...more

Cadwalader, Wickersham & Taft LLP

The Fine Print, June 2025 - The EU Makes Significant Changes to the Securitisation Regulations and Associated Prudential Rules

The EU has now published its final proposal here (the “SecReg Proposal”) for a regulation amending Regulation (EU) 2017/2402 (“SecReg”). This memo discusses the most notable changes from the 2017 version of SecReg, many of...more

Orrick, Herrington & Sutcliffe LLP

Sen. Warren pens letter against removing the enhanced supplementary leverage ratio for banks

On June 23, the Ranking Member of the U.S. Senate Committee on Banking, Housing, and Urban Affairs, Sen. Elizabeth Warren (D-MA), penned a letter raising concerns over reports that the Fed, the FDIC, and the OCC intended to...more

Orrick, Herrington & Sutcliffe LLP

Fed announces that examination programs will no longer consider reputational risk

On June 23, the Fed announced it will no longer include reputational risk as a component of its examination programs in its supervision of banks. This move will align the Fed with the OCC, which made a similar announcement in...more

Morgan Lewis - Well Done

FDA Proposes New Tool for Post-Market Scientific Assessment of Food Ingredients

On June 18, 2025, FDA announced for public comment a Post-market Assessment Prioritization Tool (Prioritization Tool) as an enhanced systematic process for post-market scientific assessment of chemicals in food, including...more

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