Spring 2024 Regulatory Agendas: SEC, CFTC, FinCEN, FRB, FDIC, OCC, and CFPB
Final and proposed rulemaking amidst legal challenges and Congressional Review Act timing
KPMG Insights:
- “Leaner” rulemaking agenda: Spring 2024 rulemaking agendas are “leaner” in comparison to 2023 agendas, likely due to the uptick in legal challenges as well as election year/Congressional Review Act timing.
- Cybersecurity risk management: Anticipate more actions on cyber risk transparency and risk management practices, including disclosures and cyber incident reporting.
- More AML/financial crime rulemaking: Multiple agencies issue (and to issue) joint and separate financial crime regulations related to customer due diligence, AML/CFT compliance, suspicious activity reporting, and information sharing.
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July 2024Looking ahead to the end of 2024 and early 2025, federal regulatory agencies (including the Securities and Exchange Commission (SEC), Commodity Futures Trading Commission (CFTC), Financial Crimes Enforcement Network (FinCEN), Federal Reserve Board (FRB), Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), and Consumer Financial Protection Bureau (CFPB)) issue their Spring 2024 Regulatory Agendas. Acting independently and together, these agendas reflect a concerted effort to enhance coordination, ensuring a more unified approach to “closing gaps” in regulatory coverage. Despite “leaner” agendas when compared to 2023, anticipated potential rulemaking includes anti-money laundering (AML) and financial crime, market structure, cybersecurity, and financial data transparency.
Notable planned final and proposed rulemakings, as well as related KPMG Regulatory Alerts, include:
Title | Stage of Rulemaking | Action Date | Related KPMG Regulatory Alerts |
|---|---|---|---|
SEC | |||
Enhanced disclosures about ESG investment practices | Final | October 2024 | |
Cybersecurity risk management for investment advisers | Final | October 2024 | |
Cybersecurity risk management rules for market entities | Final | October 2024 | |
Outsourcing by investment advisers | Final | October 2024 | |
Amendments to Regulation ATS and Regulation SCI for NMS stocks and other securities | Final | October 2024 | |
Order Competition Rule | Final | October 2024 | |
Amendments to NMS plan for the Consolidated Audit Trail- data security | Final | October 2024 | n/a |
Regulation NMS: minimum pricing increments, access fees, and transparency of better priced orders | Final | October 2024 | Click here and here |
Regulation Best Execution | Final | October 2024 | |
Regulation Systems Compliance and Integrity (Reg SCI) | Final | October 2024 | Click here and here |
Reporting of security-based swap positions | Final | October 2024 | |
Clearing agency resiliency and recovery and wind-down plans | Final | October 2024 | |
Volume-based exchange transaction pricing for NMS stocks | Final | April 2025 | |
CFTC | |||
Amendments to swap dealer capital and financial reporting requirements | Final | July 2024 (released April 2024) | |
Operational resilience framework for certain commission registrants | Final | September 2024 | |
Conflicts of interest and governance requirements for swap execution facilities | Final | September 2024 | n/a |
Event Contracts rulemaking | Proposed rule | July 2024 (released May 2024) | |
Risk management for swap dealers and futures commission merchants; Amendments | Proposed rule | January 2025 | n/a |
FinCEN | |||
Residential real estate transaction reports and records | Final | August 2024 | |
Anti-Money Laundering program and Suspicious Activity Report filing requirements for investment advisers | Final | August 2024 | |
Implementation of special measure regarding convertible virtual currency mixing, as a class of transactions of primary Money Laundering Concern | Final | December 2024 | n/a |
CIP requirements for registered investment advisers and exempt reporting advisers | Proposed | May 2024 | |
Section 6101. Establishment of National Exam and Supervision Priorities | Proposed | July 2024 | Reg Alert pending |
Section 6314. Updating whistleblower incentives and protection | Proposed | September 2024 | n/a |
Revisions to Customer Due Diligence requirements for financial institutions | Proposed | October 2024 | Click here, here, and here |
Cooperative information sharing; Protection of shared information Under Section 6103 of AML Act of 2020 | Proposed | May 2025 | n/a |
Banking Interagency | |||
Quality control standards for Automated Valuation Models | Final | July 2024 (released June 2024) | |
Long-term debt requirements for certain large BHCs, IHCs, and insured depository institutions | Final | July 2024 | |
Basel III Revisions: Amendments to the Capital Rule for large banking organizations | Final | September 2024 | |
Joint data standards required by the Financial Data Transparency Act | Proposed | July 2024 | n/a |
Anti-Money Laundering and Countering the Financing of Terrorism Programs | Proposed | July 2024 (released June 2024) | Reg Alert pending |
Incentive-based compensation arrangements | Proposed | July 2024 (released May 2024 by three of six agencies) | |
FRB | |||
Regulation H--Membership of state banking institutions in the Federal Reserve System; Reports of Suspicious Activities under Bank Secrecy Act | Final | September 2024 | n/a |
Regulation Q--Regulatory capital rules: Risk-based capital surcharges for Global Systemically Important Bank Holding Companies | Final | December 2024 | |
Regulation II -- Debit Card Interchange Fees and Routing | Final | January 2025 | |
FDIC | |||
Exemptions to Suspicious Activity Report requirements | Final | July 2024 | n/a |
Resolution Plans required for Insured Depository Institutions with $100B or more in total assets | Final | July 2024 (released June 2024) | |
Guidelines establishing standards for corporate governance and risk management for covered institutions | Final | December 2024 | |
Notifications and recordkeeping requirements for third-party service relationships | Proposed | July 2024 | n/a |
OCC | |||
Business combinations under the Bank Merger Act | Final | September 2024 | n/a |
CFPB | |||
Required rulemaking on personal financial data rights | Final | October 2024 | |
Fees for instantaneously declined transactions | Final | October 2024 | |
Overdraft lending: very large financial institutions | Final | January 2025 | |
Defining larger participants for general use digital consumer payments | Final | September 2024 | |
Fair Credit Reporting Act rulemaking | Proposed | July 2024 (released June 2024) | |
Mortgage servicing | Proposed | July 2024 | n/a |
Dive into our thinking:
Spring 2024 Regulatory Agendas: SEC, CFTC, FinCEN, FRB, FDIC, OCC, and CFPB
Final and proposed rulemaking amidst legal challenges and Congressional Review Act timing
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