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Federal Lawmakers Issue Contrasting Comment Letters on CFPB’s Section 1033 Consumer Data Rights Rulemaking
Recently, the heads of the House Financial Services Committee and a group of Democratic senators submitted competing comment letters in response to the CFPB’s August advanced notice of proposed rulemaking on consumer personal financial data rights under Section 1033 of the Dodd-Frank Act....By: Orrick, Herrington & Sutcliffe LLP
Group of U.S. House Republicans Urge Regulators to Use Discretion to Tailor Standards for Banks with $100B-$250B in Assets
On November 25, a group of House Republicans published a letter sent to the Fed, OCC and FDIC urging the agencies to reconsider how enhanced prudential standards (EPS) are applied to banks with assets between $100 billion and $250 billion....By: Orrick, Herrington & Sutcliffe LLP
The Pensions Brief: December 2025
ISSUES AFFECTING ALL SCHEMES - AUTUMN BUDGET 2025 – PENSIONS ASPECTS - The Autumn Budget contained the following key pensions-related announcements: From April 2029, the National Insurance contributions (NICs) relief on employee contributions made via a salary sacrifice arrangement will be limited to the first £2,000 of contributions each year. The NICs treatment of employer pension contributions and other employee benefits provided via salary sacrifice will be unchanged. The government has...By: Mayer Brown
CFPB Issues Two Comment Requests on Its Forms
On November 28, the CFPB issued a notice and request for comment in the Federal Register, seeking to extend the OMB’s approval for its “Consumer Response Intake Form” information collection. The intake form enables consumers to submit complaints, inquiries and feedback. That same day, the CFPB issued a similar notice and request for comment in the Federal Register for its “Consumer Complaint Intake System Company Portal Boarding Form” required under the Dodd-Frank Act. The CFPB uses the second...By: Orrick, Herrington & Sutcliffe LLP
Banking Regulators Issue RFI on Call Report Information
On December 1, the OCC, the Fed, and the FDIC issued a request for information in the Federal Register seeking input on “sources of regulatory reporting burden” for institutions that file the call reports 031, 041 and 051. The agencies invited stakeholders to identify ways to streamline call report forms and instructions as they prepare for their five-year statutory review, which requires them to eliminate any items deemed unnecessary or inappropriate....By: Orrick, Herrington & Sutcliffe LLP
FDIC Maintains 2 Percent Designated Reserve Ratio for 2026
On November 28, the FDIC published a notice in the Federal Register that the designated reserve ratio (DRR) for the deposit insurance fund will remain at 2 percent for 2026. The DRR is the target ratio of the fund balance to estimated insured deposits, as required by the Federal Deposit Insurance Act....By: Orrick, Herrington & Sutcliffe LLP
OCC Announces Actions to Reduce Regulatory Burden for Community Banks and Seeks Input on Core Service Providers
On November 24, the OCC announced a series of actions aimed at reducing regulatory burden and supporting the competitiveness of community banks. In three new bulletins, the agency: (i) released new Community Bank BSA/AML Examination Procedures designed to reduce unnecessary burdens for community banks that generally present low money laundering or terrorist financing risk; (ii) discontinued its annual Money Laundering Risk (MLR) System data collection citing the availability of less burdensome...By: Orrick, Herrington & Sutcliffe LLP
Artificial Intelligence Disclosure
Last week, the Securities and Exchange Commission’s Investor Advisory Committee met to discuss, among other things, whether to recommend to the SEC that it issue additional disclosure guidance related to artificial intelligence (AI). With some dissent, the Committee ultimately voted in favor of the recommendations (see Disclosure of Artificial Intelligence’s Impact on Operations), which are fairly prescriptive and seem consistent in spirit, in many respects, with the cybersecurity disclosure...By: Mayer Brown Free Writings + Perspectives
FDIC Extends Compliance Date for Digital Deposit Channel and ATM Signage Requirements
On November 25, the FDIC announced it would extend the compliance date for 12 C.F.R. 328.4 and 328.5 under its official signs and advertising rule from March 1, 2026, to January 1, 2027. As previously covered by InfoBytes, the agency had proposed amending the requirements for displaying the FDIC’s official digital sign on bank’s digital deposit-taking channels and ATMs to address issues and consumer confusion. The extension aligned the compliance date with the agency’s pending proposal to...By: Orrick, Herrington & Sutcliffe LLP
Prudential Regulators Finalize Rule Modifying Enhanced Supplementary Leverage Ratio Standards
On November 25, the Fed, OCC and FDIC issued a final rule modifying the enhanced supplementary leverage ratio (eSLR) standards for U.S. global systemically important bank (GSIB) holding companies and their depository institution subsidiaries. As previously covered by InfoBytes, the agencies proposed these changes in June to ensure the leverage standard serves as a backstop to risk-based capital requirements and reducing disincentives for large banking organizations to engage in low-risk...By: Orrick, Herrington & Sutcliffe LLP
UK Weekly Sanctions Update - Week of December 1, 2025
In this weekly update, we summarise the most notable updates in the UK sanctions world. RUSSIA SANCTIONS......By: Mayer Brown
FHFA Sets 2026 Multifamily Loan Purchase Caps for Fannie Mae and Freddie Mac
On November 24, the FHFA announced that the multifamily loan purchase caps for Fannie Mae and Freddie Mac (the Enterprises) in 2026 will be $88 billion each, totaling $176 billion. The announcement stated that, in 2025, at least 50 percent of each Enterprise’s multifamily loan purchases must be to mission-driven, affordable housing....By: Orrick, Herrington & Sutcliffe LLP
Illinois Supreme Court Clarifies Standing Requirement for Statutory Claims in No-Injury Cases
On November 20, the Supreme Court of Illinois issued an opinion holding that plaintiffs seeking statutory damages under the federal FCRA, including claims under the Fair and Accurate Credit Transactions Act (FACTA), must allege a concrete injury to establish standing in Illinois courts....By: Orrick, Herrington & Sutcliffe LLP
SEC Consents to Modifications to Global Research Settlement
On December 5, 2025, the Securities and Exchange Commission consented to modifications to the Global Research Settlement applicable to settling firms, which has been in place since the aftermath of the dot‑com bubble bursting. The Settlement contains an Addendum with undertakings that address conflicts of interest between research and investment banking. The Addendum includes a sunset provision providing that new rules would supersede those undertakings....By: Mayer Brown Free Writings + Perspectives
District Court Revives Review of Its Preliminary Injunction Against the CFPB
On November 26, the Trump administration and the union representing CFPB employees both replied to the U.S. District Court for the District of Columbia’s order to identify which provisions of the court’s original preliminary injunction they believed remained in force. As previously covered by InfoBytes, the D.C. district court enjoined the Trump administration’s leadership from dismantling the CFPB in March 2025. The Trump administration appealed to the U.S. Court of Appeals for the District of...By: Orrick, Herrington & Sutcliffe LLP
District Court Enters Judgment in Fraud Case Involving Escrow Transfers
On November 26, the U.S. District Court for the Central District of California entered judgment in favor of a real estate company plaintiff, concluding that the defendant, a title guaranty company, breached its duty of care by releasing more than $13 million in escrow funds without authorization from the depositor....By: Orrick, Herrington & Sutcliffe LLP
CFPB Adopts ‘Humility Pledge’ for Examinations, Says 2026 Examination Cycle is ‘Fundamentally Different’ From Prior Ones
On November 21, the CFPB’s Supervision Division announced changes to its supervision examination process, introducing a new “Humility Pledge” to be read by examiners at the start of each exam. The Bureau stated the pledge will be intended to promote greater transparency, professionalism and efficiency in supervisory exams, and will mark a shift away from prior practices. The pledge stated that, beginning with the 2026 examination cycle, the Bureau will focus its supervision resources on pressing...By: Orrick, Herrington & Sutcliffe LLP
[Video] Sunday Book Review: December 7, 2025, The Best Books on History Edition
In the Sunday Book Review, Tom Fox considers books that would interest the compliance professional, the business executive, or anyone curious. It could be books about business, compliance, history, leadership, current events, or anything else that might interest Tom. Today, we continue our review of some years’ top books in various categories as curated by the Financial Times. In this episode, we look at a history book by Frederick Studemann. 1. The Revolutionists by Jason Burke 2. Shattered...By: Thomas Fox - Compliance Evangelist
Fed Report Details Bank Conditions and Supervisory Findings for First Half of 2025
The Fed recently published its semiannual Supervision and Regulation Report on supervisory and regulatory actions, as well as current banking conditions. The report found that, in the first half of 2025, most banking organizations continued to report capital levels well above applicable regulatory requirements, with smaller banks maintaining stable liquid asset levels....By: Orrick, Herrington & Sutcliffe LLP
OCC Maintains Reduced Assessment Rates and Keeps Special Exams Unchanged for 2026
On December 1, the OCC announced its fee and assessment structure for 2026, maintaining the reduced rates implemented in September for banks and keeping the hourly fee for special examinations and investigations unchanged. OCC-regulated institutions will continue to experience decreased assessment rates; the agency is reducing the general assessment fee schedule by 30 percent for assets below $40 billion and 22 percent for assets above that. The OCC will be lowering rates for the independent...By: Orrick, Herrington & Sutcliffe LLP
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