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Bulked-Up Defense, Slimmed-Down Domestic: Inside the FY 2027 Skinny Budget
On Friday, April 3, the Trump administration released the fiscal year (FY) 2027 president’s budget request in addition to the Appendix and Analytical Perspectives. The proposed budget (“Budget”) detailed in the Appendix would reduce nondefense base discretionary funding by $73 billion to $660 billion, a 10% decrease from enacted FY26 levels, and increase defense discretionary spending by $251 billion to $1.15 trillion, a 28% increase. Total discretionary funding is increased to $1.829 trillion...By: Brownstein Hyatt Farber Schreck
Tenth Circuit grants en banc review in Colorado DIDMCA opt-out case
On April 2, the U.S. Court of Appeals for the 10th Circuit granted a petition for rehearing en banc in a case challenging Colorado’s opt-out from DIDMCA’s federal interest rate preemption framework. The 10th Circuit vacated the panel’s November 10, 2025...By: Orrick, Herrington & Sutcliffe LLP
FinCEN proposes rule to implement ‘paid’ whistleblower program
On March 30, FinCEN announced that it has issued an NPRM in the Federal Register to implement a whistleblower program which, among other things, would “pay” whistleblowers to encourage those with knowledge of potential violations of: (i) the BSA/AML; (ii) the International Emergency Economic Powers Act; (iii) the Trading With the Enemy Act; and (iv) the Foreign Narcotics Kingpin Designation Act, to voluntarily report such information. The proposed rule seeks to implement § 6314 of the Anti-Money...By: Orrick, Herrington & Sutcliffe LLP
Iowa 2026 Legislative Session – Week 12
It was another short week under the golden dome. After floor debate and committee meetings, many legislators headed back to their districts on Wednesday afternoon....By: Dentons
FINRA fines firm $450K for alleged BSA/AML, customer identification deficiencies
On March 20, FINRA received a Letter of Acceptance, Waiver, and Consent (AWC) from an online brokerage firm, censuring and fining the firm $450,000 for alleged compliance failures related to its BSA/AML program, customer identification program (CIP), and identity theft prevention program (ITPP)....By: Orrick, Herrington & Sutcliffe LLP
Democratic senators probe SEC chair on enforcement director’s resignation, withheld data, and crypto case dismissals
On March 30, two Democratic senators sent separate letters to the SEC chairman raising concerns regarding the abrupt resignation of the director of the agency’s Division of Enforcement and potential political interference in enforcement matters....By: Orrick, Herrington & Sutcliffe LLP
European Parliament Adopts CMDI Proposals
The European Parliament has published a press release announcing that it has adopted the legislative package to reform the crisis management and deposit insurance (CMDI) framework for banks in the EU. The package includes targeted amendments to the Bank Recovery and Resolution Directive (BRRD), the Single Resolution Mechanism Regulation (SRM), and the Deposit Guarantee Schemes Directive (DGSD)....By: A&O Shearman
Department of Labor Proposes Regulation On Selecting Investment Options For Individual Account Plans, Including Alternative Investments
On March 30, 2026, the United States Department of Labor (DOL) issued a proposed regulation addressing the selection of investment options for participant-directed individual account retirement plans. The proposal outlines fiduciary obligations under the Employee Retirement Income Security Act (ERISA) when selecting designated investment options, including those containing alternative assets....By: DLA Piper
UK FCA Annual Work Programme 2026/27
The UK Financial Conduct Authority (FCA) has published its annual work programme for 2026/27 setting out its planned activity for the second year of its five-year strategy....By: A&O Shearman
OCC Rescinds Recovery Planning Standards and Guidelines
Welcome to Goodwin’s Financial Services News Roundup. Our newsletter highlights important legal, regulatory, and business developments related to financial services and banking....By: Goodwin
When Participant Growth Becomes a Fiduciary Prompt — Not a Punchline
Empower recently reported that it added approximately 500,000 net new retirement plan participants in 2025 as part of what it termed a record earnings year. It’s the kind of headline that gets shared on LinkedIn, quoted at conferences, and sometimes recited back to committees as proof that “things are trending in the right direction.” But as plan providers, we have to separate PR metrics from fiduciary reality....By: Ary Rosenbaum - The Rosenbaum Law Firm P.C.
United States: The Last Leg: SEC Extends Trading Relief to Share Class ETFs
With this fourth SEC approval, share class ETFs are now ready to go live. Since late 2025, the SEC has provided exemptive relief to dozens of managers under Section 18(f), among other provisions, for mutual funds to issue a share class listed separately as an ETF. In addition to these orders, the SEC has approved generic listing standards of these ETFs on the exchanges and, more recently, registration statements for these ETFs are now effective....By: K&L Gates LLP
House Financial Services subcommittee examines how financial regulators adapt to industry innovation
On March 26, the House Financial Services Subcommittee on Digital Assets, Financial Technology, and Artificial Intelligence held a hearing examining the degree to which federal financial regulators are adapting to new technologies and products in banking and consumer finance, and whether their current organizational structures allow them to do so effectively....By: Orrick, Herrington & Sutcliffe LLP
For Whom the Interest Tolls
A significant part of the amounts due to a lender in a mortgage foreclosure action is interest on the outstanding principal. Sometimes the actions (or inaction) of a lender can result in significant reductions in the amount of interest awarded to it in a foreclosure action....By: Freiberger Haber LLP
FDIC publishes February enforcement actions
On March 27, the FDIC published a list of administrative and enforcement actions taken in February. The list of nine actions consists of one consent order, one order of prohibition, six orders terminating a total of 100 waiver orders, and one notice....By: Orrick, Herrington & Sutcliffe LLP
[Video] Sunday Book Review: April 5, 2026, The Top Books for Export Controls/Sanctions Edition
In the Sunday Book Review, Tom Fox considers books that would interest compliance professionals, business executives, or anyone curious. It could be books about business, compliance, history, leadership, current events, or anything else that might interest Tom. In this episode, we look at 4 top books that every export control and sanctions professional should read, as curated by Mike Huneke. • Confessions of an Economic Hitman by John Perkins • Red Notice: A True Story of High Finance, Murder,...By: Thomas Fox - Compliance Evangelist
UK Public M&A Monthly Activity Update: March 2026
In March 2026, there were three Rule 2.7 announcements made across the UK public M&A market and seven further possible offers / sale processes announced....By: Herbert Smith Freehills Kramer
Arizona Breaks New Ground with Criminal Charger Against Prediction Market Platform
Arizona Attorney General Kris Mayes made regulatory history by filing the first-ever criminal charges against a prediction market platform for allegedly operating an illegal gambling business in the state....By: Sheppard, Mullin, Richter & Hampton LLP
Private Credit 2026
Looking back on 2025 and looking forward into 2026, the rapidly growing private credit market has emerged as a formidable force in the global financial landscape, offering a compelling alternative to traditional syndicated bank lending and other public market products including high-yield bonds. This Chambers 2026 Private Credit guide provides an overview of trends and developments in the private credit market in the most active jurisdictions, including the United States, the UK and beyond....By: Latham & Watkins LLP
FCA’s Regulatory Priorities in Wholesale Markets: New Insights of Importance for Investment Banks - April 2026
When the FCA announced that it would move away from issuing portfolio letters (seemingly to sometimes ill-defined sectors, and at random intervals) with a focused, annual, pre-set list of sectors, this approach received widespread market support. Helpfully, the FCA has now defined the nine sectors that will receive annual updates in its Regulatory Priorities reports, and the cadence at which these documents will appear. Predictability and clarity in regulatory expectations is, of course,...By: Latham & Watkins LLP
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