Regulatory Alerts
Quick hitting summaries of specific regulatory developments and their impact.
No results found.
Capital Proposals
Basel III Amendments, Revised Standardized Approach, GSIB Surcharge
Prediction Markets: CFTC Advisory and ANPR
Responsibilities of DCMs in listing and trading event contracts
DOJ Extends Corporate Enforcement Policy Department-Wide
Encouraging voluntary self-disclosure, meaningful cooperation, and good-faith remediation
Cybersecurity: New Cyber Strategy; Cybercrime Executive Order
Long-term policies and near-term priorities
Gaining Momentum
Bank Charter Activity
Financial Services Bank Regulatory Tailoring
From statements to action
State AI Safety Laws: California and New York
Safety Protocols, Incident Reporting, Civil Penalties
Cybersecurity: NIST Draft Cybersecurity Framework for AI
AI-specific considerations layered into the CSF 2.0
Cybersecurity: NIST/CISA Draft Report on Protecting Tokens and Assertions
Managing digital identity against forgery, theft, and misuse
OCC Heightened Standards: Proposed Amendments
Significant change to the applicable asset threshold
OCC Proposal: Simplified CRA Strategic Plan for Community Banks
New form; streamlined process; same requirements
No results found.
FDIC Proposal: Application Process for Payment Stablecoin Issuers
Aligns with GENIUS Act; additional proposals to follow
Executive Order: National Policy Framework for AI
Promotes innovation, limits regulatory fragmentation, potential preemption
FRB Reports: Supervision and Regulation; Financial Stability
Declines in supervisory findings; changes to the supervisory action framework
Enhanced Supplementary Leverage Ratio (eSLR): Final Amendments
Impacts to eSLR, LTD, and TLAC Requirements
Community Banking: Regulatory Tailoring Actions and Proposals
Ongoing Efforts to Ease Requirements
Federal Reserve: Supervisory Operating Principles
Examiner Guidance for 2026
SEC 2026 Priorities: Examinations and Perspectives
Examiner Guidance for 2026
CFPB Proposal: Small Business Lending Data (Section 1071)
Narrowing the scope for covered institutions and data collection points
Capital: FRB Proposed Rules on Stress Testing Transparency
A focus on transparency
FRB Rating Systems: Final Changes to the LFI Framework
Modifications to the definition of “well managed”
CFPB Small Business Lending Data (Section 1071)
Final rule governing data collection and reporting
FinCEN: FAQs on Suspicious Activity Reporting
Clarifying current expectations; signaling more "modernization" efforts to come
Cybersecurity: DoD Final Rule on CMMC Contract Requirements
Three-year phase-in; Varying based on sensitivity/risk
State Series: Drug Pricing
Oversight, reporting, and access/affordability
MAHA Commission Strategy Report
More than 120 Initiatives impacting multiple industries/sectors
Regulatory Agendas: SEC, CFTC, FinCEN, FRB, FDIC, OCC, and CFPB
Anticipated final and proposed rulemakings
State Series: Antitrust and M&A
Potential Impacts to Deals and Mergers
State Series: Property & Casualty Insurance
Market dynamics driving regulatory actions
State Series: Financial Consumer Protections
Increasing state legislative and enforcement activity
Executive Order: “Debanking”/“Fair Banking”
Reviews, reassessment, look-backs, and remediation
Executive Order: 401(k) Investor Access to Alternative Assets
Reassessment of ERISA
State Series: AI Legislation
More than 1,000 bills across 50 states
AI Action Plan and Executive Orders
Policies to promote innovation, infrastructure and diplomacy and security
Crypto and Digital Assets: Final GENIUS Act and Other Actions
Landmark stablecoin bill passes; market structure bill moves to the Senate
FRB Rating Systems: Proposal to Modify the LFI Framework
Changes to the definition of “well managed”
FinCEN: Recent Orders and Actions
BSA/AML/CFT
GENIUS Act: Payment Stablecoin Framework – Senate Approves
Bill now moves to the House for consideration
Enhanced Supplementary Leverage Ratio (eSLR): Proposed Amendments
First step in proposed changes to regulatory capital
Focus on Children’s Online Privacy Protections
Strengthening protections for collection, use, and retention of children’s personal information
Tariff, Trade, and Customs Fraud/Evasion
Expanding use of existing authorities to prioritize investigations and enforcement
SEC Speaks: What to Watch in 2025
Highlights on new regulations, enforcements, and public interaction
Upcoming Regulatory Changes in/to Financial Risk
Tailoring, Capital, Stress Testing, Resolution Planning
First 100 Days: Upcoming Regulatory Signals for Fraud and Financial Crime
Actions impacting Fraud, BSA/AML/CFT, Bribery/Corruption, and Sanctions
Special Alert: DOJ Announces Revisions to Corporate Enforcement Policies
Voluntary self-disclosure, monitor selection, whistleblower tips
Special Alert: DOJ Final Rule Prohibiting Access to Bulk U.S. Sensitive Personal Data
Restrictions on certain data transactions
First 100 Days: Upcoming Regulatory Signals for M&A and Capital Formation
Signals will help to guide the deregulatory agenda
First 100 Days: Upcoming Regulatory Signals for Digital Assets
Charting a New Regulatory Path
First 100 Days: Upcoming Regulatory Signals for Cyber and Privacy
Shifts at the Federal Level; Increasing Role for States
Special Alert: CTA Beneficial Ownership Information (BOI) Reporting
Interim Final Rule Narrows Reporting to Foreign Companies
First 100 Days: Upcoming Regulatory Signals for AI
Federal and State Regulatory Shifts
Fraud, Identity Theft, and Other Scams
2024 FTC Data Book Insights
Special Alert: Digital Assets/Cryptocurrency Regulation
Regulatory shifts related to establishing a framework for crypto assets
First 100 Days: Upcoming Regulatory Signals for ‘Deregulation’
Regulatory shifts based on executive/legislative and agency actions/directions
SEC Amended Final Rules: Clearing for US Treasury Securities
Compliance Extension, Temporary Exemption
First 100 Days: Upcoming Regulatory Signals for Private Equity
Indicators of potential regulatory shifts to agency objectives and regulatory focus
First 100 Days: Upcoming Regulatory Signals for Healthcare/Life Sciences
Indicators of potential regulatory shifts to agency objectives and regulatory focus
First 100 Days: Upcoming Regulatory Signals for Energy
Indicators of potential regulatory shifts to agency objectives and regulatory focus
First 100 Days: Upcoming Regulatory Signals for Consumer/Retail
Indicators of potential regulatory shifts to agency objectives and regulatory focus
First 100 Days: Upcoming Regulatory Signals for Industrial Manufacturing & Auto
Indicators of potential regulatory shifts to agency objectives and regulatory focus
Special Alert: New CFPB Acting Director; Additional Pauses on CFPB Activities
Halt to supervision and examination activity in addition to new and pending investigations and enforcements
Special Alert: DOJ Signals – FCPA and Money Laundering Enforcement
New enforcement priorities in the Criminal Division
First 100 Days: Upcoming Regulatory Signals for Tech, Media & Telecom
A focus on deregulation, national security, and AI
First 100 Days: Upcoming Regulatory Signals for Financial Services
Indicators of potential regulatory shifts to agency mission/operations and regulatory focus
Privacy: FTC Finalizes Children’s Online Privacy (COPPA) Amendments
Amendment to increase restrictions on the collection, use, and disclosure of children’s personal information
Day One: Order on Digital Assets/Crypto Order (and SEC SAB 121)
First action toward a "crypto policy"
Day One: Orders on "Regulatory Freeze", AI, Climate/Environment
Flurry of actions; more to come across an array of policy areas
AI and Privacy: A Look at Biometric Tech & Data
Expanding definition of biometric data elements and technology applications
Data Centers, AI and Energy Confluences: Expected Regulatory Shifts in the New Administration
Changing regulations with increasing energy demands
No results found.
Data Brokers and Data Protection: Regulatory Actions
Federal/State Enforcement, Guidance, Proposal
SEC FY 2024 Enforcement Actions & Leadership Changes
Record-Breaking Activity and Chair Resignation
Supervision of Nonbank Digital Wallet/Payment Providers: CFPB Final Rule
Establishes supervision and examination authority
Recovery Planning: OCC Final Rule
Expanding coverage to include $100B banks and consideration of financial and non-financial risks
1033 Open Banking: CFPB Final Rule
Personal Financial Data Rights
SEC 2025 Priorities: Examinations and Perspectives
Key Risks, Exam Priorities, and Policy Perspectives
Premerger Notification: FTC and DOJ Final Amendments
Antitrust Focus in the M&A Process
Corporate Compliance: DOJ Evaluation Updates/Pilot Programs
Changes to evaluations focusing on data access, resource allocation, and risk management of new technologies
Market Rules: NMS SEC Amendments
Tick Sizes, Access Fees, and Order Pricing Transparency
Bank-Third Party: Custodial Deposit Account Recordkeeping Proposal
Enhanced requirements to strengthen beneficial ownership and deposit insurance protections in custodial deposit accounts
Bank Mergers: FDIC and OCC Policies/Amendments
Principle-based approaches to bank merger evaluations
Spring 2024 Regulatory Agendas: SEC, CFTC, FinCEN, FRB, FDIC, OCC, and CFPB
Final and proposed rulemaking amidst legal challenges and Congressional Review Act timing
Joint Data Standards: Interagency Proposal
Eight financial services agencies and Treasury propose data standards to promote interoperability
Investment Company Reporting on Forms N-PORT and N-CEN: SEC Final Rule
Enhancing financial transparency of investment funds
Capital: FRB Remarks Outlining Basel III Endgame Re-Proposal
Potential changes to tailor applicability and recalibrate risk areas (credit, operational, market)
Financial Crime & AML: FinCEN Final Rule for Investment Advisers
AML/CFT program and suspicious activity reporting requirements
Financial Crime & AML: FinCEN Final Rule on Real Estate Transfer Reporting
Reporting on non-financed transactions in the residential real estate market
New AI Actions: White House Announcement; NIST, NTIA Guidance
GenAI risk management and software development, global AI standards, foundation model risks (“open-weight models”, misuse)
Resolution & Living Wills: FDIC/FRB Final Guidance
Expectations, regardless of strategy, around capital, liquidity, governance, and operations
Regulatory Focus: Third Party, "Nth" Parties, Intermediaries & Service Providers
Growing focus on risk management programs and robust governance practices across all relationships and activities
Recovery Planning: OCC Proposed Rule
Expanding coverage to include $100B+ banks and financial and non-financial risks
Proposal to Strengthen AML/CFT Programs Under BSA
Navigating the New AML/CFT Compliance Landscape
Final Interagency Actions: Automated Valuation Models (AVMs), Reconsideration of Value
Quality control factors
Resolution Plans: FDIC Final Rule
Resolution analysis, submissions, and filings
Colorado Artificial Intelligence Act (CAIA)
Developers and deployers protections against “algorithmic discrimination”
Cybersecurity Strategy: ONCD, GAO
Cross-sector harmony and reciprocity in cyber regulation
SEC Risk Alert: Examining Broker-Dealers
Selection, scope, and document requests
Buy Now, Pay Later (BNPL): CFPB Rule on Consumer Protections
Existing consumer protections for credit cards apply to BNPL credit
Gaming and Event Contracts: CFTC Proposed Amendments/Prohibitions
Clarifies “gaming” activities and other types of event contracts prohibited from trading or clearing
Customer Identification Program (CIP): SEC/FinCEN RIA/ERA Proposal
Proposal to expands customer identity program obligations—verification and documentation—to investment advisers
Regulation S-P: SEC Final Amendments
Incident response programs, customer notifications, expanded coverage
NIST Draft AI Guidance, Report, and Global Plan
Covering GenAI-related risk management and software development, synthetic content risks in AI, and global AI standards collaboration
AI Policy Roadmap: Senate AI Working Group
Recommends funding priorities, legislative/regulatory actions, and areas for further study or consideration
FRB Reports: Supervision and Regulation; Financial Stability
Increasing supervisory findings and declining ratings at banks of all sizes; focus on governance/controls and IT/operational risk
Climate Risk: FRB Report on Scenario Analysis Pilot
Acknowledging differences in approach and data challenges
Incentive-based Compensation: Interagency Proposed Rule
Seeks to curb “excessive risk-taking” and align compensation with sound risk management
Investment Advice Fiduciary: DOL Final Retirement Security Rule
Expanded definitions of investment advice and recommendations
Heightened Risk Standards: Focus on Trade Surveillance
Mitigating operational and market conduct risk
Risk Alert: SEC Marketing Rule Compliance
Focus on true, fair, and balanced advertising
Consumer Complaints: CFPB Analysis of 2023
Key Findings and Insights from Over One Million Complaints
SEC Speaks: Recap of 2023 Actions
Highlights related to enforcements, examinations, and rulemaking activities
Data Retention and Deletion: Devices and E-Comms
Ongoing enforcement trends and rulemakings highlight regulators’ focus on data capture, retention, and deletion
SEC Examinations Risk Alert: T+1 Settlement Cycle
Assessing preparedness for the shift to a shortened settlement cycle
Emerging Regulatory Focus: Operational Resilience
Identification of critical operations, disruption tolerances, and robust third-party oversight
Physical Security: New CA Workplace Law
New requirements for workplace security
SEC Final Amendments: Rule 605 of Regulation NMS
Expanding coverage and disclosure for execution of orders in NMS stocks
SEC Climate-Related Disclosure: Final Rule
Less in final disclosures but anticipate continued regulatory focus on climate risk management, controls, data, analysis and testing
Credit Card Late Fees: CFPB Final Rule
Changes to credit card late fees for larger card issuers
Regulatory Perimeter: Expanding Financial Service Coverage
Acting independently and together financial services regulators are “closing gaps” in regulatory coverage
NAIC 2024 Strategic Priorities for State Insurance Regulators
Focus areas including climate risk, AI/Cyber risks, marketing, oversight/transparency, and consumer protections
Heightened Risk Standards: Focus on Data Management (& BCBS 239)
Intensified scrutiny of risk data management/governance practices
Fraud, Identity Theft, and Other Scams
2023 FTC Data Book Insights
Financial Crimes & AML: FinCEN Proposal and Treasury Actions
Treasury and FinCEN actions to assess and strengthen AML/CFT/BSA coverage
Form PF Reporting: SEC, CFTC Joint Final Rule
Expanded reporting requirements for investment advisers to private funds, including hedge funds
Heightened Risk Standards: Focus on Internal Controls and Operational Risk
Increased regulatory scrutiny in the management of Internal Controls and Operational Risk
Dealer Definition: SEC Final Amendments
Expansion of registration and coverage to traders/hedge funds engaging in liquidity-providing roles
Heightened Risk Standards: Focus on AML/BSA
Increased regulatory scrutiny in the management of AML/BSA
AI Regulation: Cross-Agency Actions
“Whole-of-government” execution of Executive Order to establish safe, secure, and trustworthy AI
Fees: CFPB Overdraft Lending Proposed Rule
Directed to financial institutions over $10B; would limit fees and exemptions
Swaps: SEC Examinations Risk Alert; CFTC Proposals
To strengthen reporting, recordkeeping, risk management, and operational resilience
Privacy: FTC NPR to Children’s Online Privacy (COPPA)
Amendment to increase restrictions on the collection, use, and disclosure of children’s personal information
Regulatory Oversight: FINRA 2024 Annual Report
Key supervisory risk areas
FRB Supervision and Regulation Report
Continued increase in supervisory findings and declining ratings at banks of all sizes; focus on governance/controls and IT/operational risk
SEC Approves Firsts in Listing/Trading of Spot Bitcoin ETPs
Ongoing focus on investor protections, disclosure requirements, standards of conduct, and exchange rules
Anti-bribery: Extension of Prohibitions to “Foreign Officials”
New anti-corruption/ anti-bribery focus includes demand, receipt, or acceptance of bribes by “foreign officials”, expanding upon FCPA
Commercial Real Estate (CRE): Expanded Regulatory Focus
Reports/guidance emphasize CRE challenges and risk mitigation
Antitrust: DOJ/FTC 2023 Merger Guidelines
11 guideline areas for all industries/sectors
FinCEN CTA: Final Rule on Beneficial Ownership Information Access
CTA final rule establishes who may access, for what purposes, and necessary safeguards; second of three related rulemakings
Capital: FRB Remarks Outlining Basel III Endgame Re-Proposal
Potential changes to tailor applicability and recalibrate risk areas (credit, operational, market)
No results found.
FDIC Deposit Insurance Signage and Advertising: Final Rule
Focus on responsible advertising and clarity of insured versus non-insured products
AI Actions: NIST RFI
Guidelines coming for AI evaluation, red-teaming, “and more”
U.S. Treasury Securities Clearing Agency Standards: SEC Final Rule
Enhanced treasury securities risk management practices, customer protections, and clearing & settlement standards
Illicit Finance & Corruption: Treasury Actions
Efforts to thwart threats posed by illicit finance, money laundering, sanctions evasion and corruption
Fall 2023 Regulatory Agendas: Key Federal Banking Agencies
Key list of upcoming rulemakings
Landmark Actions Coming: The AI Act and Growing US Regulations
“Whole-of-government” actions increasing as agencies intensify their focus on safe, secure, and trustworthy AI/GenAI
Analysis of Regulations: OMB Circular A-4 Cost-Benefit Updates
Revisions to expand consideration of societal costs/benefits and indirect impacts, with longer time horizons and lower discount rates
SEC Fall 2023 Regulatory Agenda
Notable planned final and proposed rulemakings continue to be recognized in the Agenda stages of rulemaking
Noncompliance with Laws and Regulations, Including Fraud: PCAOB Proposed Amendments
Potential areas for company risk focus
FRB Reports: Supervision and Regulation; Financial Stability
Semiannual reports highlighting supervisory and regulatory developments, supervisory priorities, and financial system risks
CFPB Proposal to Supervise Big Tech and Other Wallet/Payment Providers
Proposal to supervise “larger participants” in the nonbank market for “general-use consumer digital payment applications”
Financial Stability, Nonbank Supervision: FSOC Final Guidance
Analytic Framework and Guidance for identifying, assessing, and responding to potential bank and nonbank financial stability risks
DOJ Safe Harbor Policy for Voluntary Self-Disclosures in Mergers & Acquisitions
DOJ Safe Harbor Policy for Voluntary Self-Disclosures in M&A
Executive Order on Safe, Secure, and Trustworthy AI
Call for AI risk management actions/standards for privacy, security, consumer/worker protections, and innovation
Debit Interchange Fee Cap: FRB Reg II Proposed Amendments
Proposal to amend the interchange fee cap and methodology
Final Principles for Climate-Related Financial Risk Management
Interagency guidance for banks over $100B to identify, measure, monitor, and control climate-related financial risks
Community Reinvestment Act: Interagency Final Rule
Updated CRA framework recognizing “branchless” banking and clarifying CRA-eligible activities, metrics/benchmarks and processes
”Open Banking” 1033 Personal Financial Data Rights: CFPB Proposal
Proposal to provide consumers “more control” over their personal financial data related to deposit, savings, and credit cards accounts
Short Sale Reporting: SEC Final Rule
New rule and Form SHO for monthly reporting of gross short sale positions and “net” activity by institutional investment managers
Reporting of Securities Loans: SEC Final Rule
Daily reporting requirements and publication of information for covered securities loans and related modifications on most securities
Volume-based Transaction Pricing: SEC Proposed Rule
Proposal to prohibit pricing for agency-related orders and to require disclosures around pricing tiers and membership
Examinations: SEC 2024 Priorities
Focus areas include marketing practices, conflicts of interest, operational resiliency, and emerging financial technology
“Junk Fees” Actions: FTC, CFPB, FCC, HUD, DOT, State
Ongoing “whole of government” actions to prohibit “hidden” and “falsely advertised” fees from consumer products and services
SEC Beneficial Ownership Reporting Amendments
Shorter reporting timeframes for investors with more than a 5 percent beneficial ownership of a covered class of equity securities
Expanded Risk Governance and Management: FDIC Proposed Guidelines
Expectations for board governance and for board and management risk management responsibilities
CA Climate Laws: GHG Emissions and Risk Reporting
New CA laws requiring measurement and reporting of GHG emissions (Scopes 1, 2, and 3) and climate-related financial risks
Consumer/Worker Protections: FTC, FCC, and DOL Sign MOUs
Agreements to protect consumers from electronic spam/scams and workers from unfair competition/business practices
Names Rule: SEC Final Amendments
Preventing Misleading or Deceptive Fund Names, September 2023
Risk Alert: SEC Investment Adviser Supervision
Insights into the selection of advisers for exams, including risk factors, and document requests
Long-Term Debt Requirements: Interagency Proposed Rule
Proposal to impose a LTD requirement on certain large BHCs, IHCs, and insured depository institutions
SEC Private Fund Adviser Reforms: Final Rules
Increased reporting/disclosure to investors; new compliance documentation requirements for all registered advisers
AML Enforcement: SEC Risk Alert & FFIEC Exam Manual Updates
Increasing intensity to AML programs, customer identification programs, CDD, and beneficial ownership obligations
“Covered Technologies” and Conflicts of Interest: SEC Proposal
To address conflicts arising from technologies that optimize for, predict, guide, forecast, or direct investor decisions
Resolution & Living Wills: FDIC and Joint (FDIC/FRB) proposals
Strengthening resolution planning, strategy, and reporting
Capital Requirements: Proposed “Basel III Endgame” & GSIB Capital Surcharges
Intended to introduce more transparency, consistency, and risk sensitivity to the frameworks
Public Company Cybersecurity Risk Management, Strategy, Governance and Incident Disclosure
SEC Final Rule
SEC Money Market Fund Reforms & Customer Protection Rule Proposal
SEC efforts to improve fund resiliency and stability
2023 Regulatory Agendas: Federal Banking Regulators
Key list of upcoming rulemaking
SEC 2023 Regulatory Agenda
Continuing a brisk pace and breadth of activity
Interagency Proposals: Automated Valuation Models; Reconsideration of Value
Implementing new automated valuation model quality control standards
SEC Examinations Risk Alert: Marketing Rule
Expanding examinations focus on testimonials and endorsements, third-party ratings, and Form ADV disclosures
Third-Party Risk Management (TPRM): Final Interagency Guidance
Replaces each agency’s prior third-party guidance; reiterates sound risk management
Bank Supervision: OCC “Persistent Weaknesses”
Reiterating the importance of bank risk management, issues management, and governance
Biometric Information: Federal Trade Commission UDAP
Policy statement on the collection and use of “biometric information”
Supervisory Focus: FRB Highlights
FRB Reports: Supervision and Regulation, Financial Stability
Clearing Agency Risk Management and “Living Wills”
Proposed changes to the Covered Clearing Agency Standards impacting margin requirements and the elements of recovery and wind-down plans
Form PF and Share Repurchase Disclosures: Final Rules
Expands investment adviser Form PF reporting and issuer disclosure of share repurchase plans and activity
FDIC Deposit Insurance Reform Options
Potential alternatives to the current deposit insurance system
Bank Supervision and Regulatory Change
Federal push for changes to financial services supervision and regulation
Enforcement/Supervision to “Automated Systems”
Ensuring “automated systems” development and use is consistent with federal laws
Financial Stability, Nonbank Supervision: FSOC Proposals
Analytic framework and related guidance for identifying, assessing, and responding to potential financial stability risks
Environmental Justice: New Executive Order
White House says “environmental justice is a duty of all executive branch agencies and should be incorporated into their missions”
Ensuring Trust in AI: Commerce Department Request for Comment
Seeking input on how to ensure that AI works as claimed and without causing harms
Bank Regulatory Change
Administration encourages federal banking agencies to make regulatory and supervisory changes
CFPB Small Business Lending Data (Section 1071)
Final rule governing data collection and reporting
FTC Recent Focus on Tech: Digital Advertising, Cloud
Increasing scrutiny of technology adoption and use
SEC Proposal to Expand Regulation SCI
Areas of focus: policies/procedures, incident notification, and system reviews/testing
SEC Proposals on Cyber Risk Management for Market Entities
Areas of focus: policies/procedures, cyber risk assessments, incident notification/disclosure, expanded coverage among participants
SEC Proposes Amendments to Regulation S-P
Changes to the Safeguards and Disposal Rules to address detection and notification of customer data breaches
DOJ Initiatives on Compensation, Voluntary Self-Disclosure
Continuing focus on accountability and cooperation
White House Announces National Cybersecurity Strategy
Calls to shift liability and investment and promote secure and resilient software products/services
Fraud, Identity Theft, and Other Scams
Approximately 5.15 million reports received from consumers in 2022
Russia-Ukraine War: Expanded U.S. Sanctions, FATF Action
U.S., G7, and other countries announce “expanded and intensified” Russia sanctions and set price caps on Russian-origin petroleum products
NAIC 2023 Strategic Priorities for State Insurance Regulators
Focus areas including climate risk, data/AI, cybersecurity, marketing, and consumer protections
SEC Proposes Amendments to the Custody Rule
Expands authority to all assets, including crypto
SEC final rule for T+1 settlement cycle
Shortening the securities transaction settlement cycle
Focus on Tech: Cloud, AI, Personal Data
Heightened regulatory expectations for technology risk management, operational resiliency, risk governance, data collection and privacy
Examinations: SEC 2023 Priorities
Focus areas include adherence to new rules, RIAs to private funds, retail investor “best interest” ESG-related services/funds, and “crypto-related” trading
Consumer Fees: CFPB Proposal on Credit Card Late Fees
Continued focus on consumer fees and “fairness”
SEC Examinations Risk Alert: Regulation Best Interest
Observations across the four components: Disclosure, Care, Conflict of Interest, and Compliance
DOJ Revises Criminal Division Corporate Enforcement Policy
"Benefits" for self-disclosure, cooperation, and remediation
Climate Risk: FRB’s Pilot Scenario Analysis and Risk Management Practices
Quantitative and qualitative measures for assessing impact of physical and transition risk
Examination and Risk Monitoring: FINRA 2023 Report
Outline of key risk areas and new topics
CFPB Proposal to Supervise Big Tech and Other Wallet/Payment Providers
Proposal to supervise “larger participants” in the nonbank market for “general-use consumer digital payment applications”
CFPB Regulatory Agenda
Continuing focus on fees
SEC Regulatory Agenda
Continuing its ambitious pace and breadth of activity
No results found.
Focus on Non-Bank Financial Firms, P2P Platforms, and Crypto Exchanges
Banks and non-banks should anticipate heightened regulatory attention
FRB Reports: Financial stability risks; Supervision and regulatory priorities
Large banks mitigate financial uncertainties; the FRB denotes “work to do” to meet supervisory expectations for governance and controls
Bank Lending: FRB Survey Indicates Industry Expects Mild Recession, Tightening Standards
Tightening of standards and terms across business loans; increased demand for credit card loans and HELOCs
Third party risk management: SEC Investment Adviser Proposal
New proposed oversight requirements for investment advisers using third party service providers
CFPB Proposals for Section 1033, Personal Financial Data Rights
Outline of proposals to implement section 1033 of the Dodd-Frank Act
Data Retention and Deletion: Increasing Regulatory Expectations
Regulators have heightened rulemaking and enforcement to strengthen recordkeeping, data retention, and data deletion requirements
Climate Risk: Insurance data collection; FSB progress reports
Continued focus on climate-related financial risks, related disclosures, and prudential oversight
Large Bank Resolution: FRB, FDIC Joint ANPR
Increasing concentration in the $250-$700 billion asset size prompts regulators to consider changes to LBO resolution requirements
Crypto and Digital Assets: FSOC, NY Fed Reports on Financial Stability Implications
Detailed reports on the financial stability risks of digital assets
Climate Risk: SEC’s Mandatory Climate Disclosures Proposal
Quantitative and qualitative elements would have far-reaching impacts
Climate Risk: FRB pilot scenario analysis
Measuring and managing climate-related risks
Crypto & Digital Assets: Treasury & DOJ Report Recommendations
A look at recommendations to inform future policies, including consumer/investor protections, financial crimes, and national security
DOJ shifts policies, encouraging compliance "incentives and deterrence"
Enhancing and investing in the ethics & compliance program
Regulation and supervision: Agencies preview forthcoming priorities
Key upcoming areas of focus
Inflation Reduction Act
Provisions to address energy production, carbon emissions reduction
OCC principles for large bank climate risk management
Large banks on notice for maturation of climate risk management programs
2021
Money market fund reforms
Insider Trading and Share Repurchases
Countering corruption: Beneficial ownership, Real-estate transactions
Regulatory focus on overdraft fees
Cryptocurrency activities
Cyber incident notifications
DOJ shifts policies, encourages companies to focus on compliance investment
Virtual assets and related providers | Updated FATF guidance
Infrastructure law adds new funding avenues
Board action: Climate risk questions for management
Interagency Report on Regulation of Stablecoins
CFPB issues consumer protection orders to Big Tech
FSOC issues climate risk recommendations
Transition away from LIBOR
Regulatory focus on cloud computing
CFPB supervisory and enforcement focus
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