Insights

Banking Regulators Replace Comprehensive Model Risk Management Guidance with Risk-Based Approach

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Summary Situation Overview: On April 17, 2026, the Federal Reserve Board, the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) jointly issued revised model risk management (MRM) guidance,…

Understanding Regulatory Attention on Private Assets and AI Across Capital Markets and Insurance

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Summary Situation Overview: Private assets and artificial intelligence (AI) are playing an increasingly prominent role across the financial system, including in capital markets and insurance. These developments are unfolding against a backdrop…

Regulatory Key Non-Financial Focus Areas: Financial Crimes, Fintechs, Digital Assets and AI

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Summary Situation Overview: Against the backdrop of deregulation, we expect regulators to continue to focus on financial crimes as well as fintech partnerships, digital assets, and artificial intelligence (AI). What: Firms must keep compliance…

Understanding the New De-Banking Executive Order

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Summary: Situation Overview: On August 7, 2025, President Trump issued an Executive Order (the “Order”) entitled “Guaranteeing Fair Banking for All Americans”, which has implications for retail and institutional fair lending practices. What:…

CFPB Initiates New Rulemaking for Section 1033

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Summary: Situation Overview: On 21 August, the Consumer Financial Protection Bureau (CFPB) issued an Advanced Notice of Proposed Rulemaking (ANPR) regarding Section 1033 of the Consumer Financial Protection Act. What: Many fintech companies,…

American Bankers Association Conference Focused on AI

Summary: Situation Overview: The 2025 American Bankers Association (ABA) Risk and Compliance Conference heavily focused on Artificial Intelligence (AI) in Banking – including top use cases and best practices in AI governance.  What: The…

Fed Withdrawal of Guidance Marks Milestone for Banks’ Future Crypto Activity

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Summary: Situation Overview: The federal banking agencies have withdrawn previously issued guidance related to banks’ crypto activities, marking a shift in regulatory posture toward digital asset engagement. What: On April 25, the Federal…

FDIC Highlights Policy Priorities Impacting FinTechs and Large Banks

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Summary: Situation Overview: FDIC is focused on de novo bank formation, digital assets and blockchain activities, resolution planning, and asset thresholds for “tailoring” categories. What: The FDIC is reevaluating guidance in these…

Fast Company: Silicon Valley Bank: An ‘It’s a Wonderful Life’ bank run for the digital age

Federal Reserve Hardens Stance Towards Crypto, Denies Bank Membership

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What’s Happening Federal Reserve (FRB) denies membership and master account application for state-chartered Custodia Bank with crypto-focused business model FRB presumptively prohibits banks it supervises from holding crypto as principal…

OCC Acting Comptroller Discusses “Too Big to Manage” Banks, Four-Step Escalation Framework

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Acting Comptroller of the Currency Michael Hsu presents a framework for scrutinizing banks viewed as “too big to manage.” Hsu describes a four-step escalation framework for supervisory issues, with a “credible threat of restrictions…
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By: Chris Beckmann, Bryan Hubbard, Keith Noreika

Banking Regulators Send Strong Warning About Crypto Risks

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Federal banking agencies encourage banks to monitor crypto risks, stress importance of keeping crypto sector risks isolated from broader financial system. Regulators view open, public or decentralized networks as highly likely to be inconsistent…