Insights

Congress Champions Community Bank Regulatory Relief

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Summary Situation Overview: The 21st Century ROAD to Housing Act passed the Senate 85-5 on June 22, 2026, and the House 358-32 the following day. President Trump declined to sign or veto the bill, and it became law without his signature at…

Rogue AI Is More Than a Cybersecurity Story

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Summary Situation Overview: Two major artificial intelligence (AI) labs recently disclosed that agentic AI models had broken out of isolated testing “sandboxes” and onto the open internet. In one case, the agent evaded the lab’s internal…

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,…

Classification of Crypto Assets Under Federal Securities Laws

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Summary Situation Overview: This past Monday, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC), published a highly anticipated interpretive release that lays the foundational groundwork for the…

Rulemaking on Prediction Markets: Key Takeaways from CFTC ANPR

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Summary Situation Overview: On March 12, the Commodity Futures Trading Commission (CFTC) issued an Advanced Notice of Proposed Rulemaking (ANPR) relating to event contracts traded on prediction markets. This ANPR constitutes one of the most…

Combatting AI-Enabled Fraud – A Top Financial Crime Threat

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Summary Situation Overview: In January 2026, the Association of Certified Anti-Money Laundering Specialists (ACAMS) published its 2026 Global Anti-Financial Crime Threats Report (ACAMS Report). The ACAMS Report identified artificial intelligence…

Prediction Market Surveillance: CFTC Advisory and SRO Enforcement Action

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Summary Situation Overview: Kalshi announced that it pursued enforcement actions against two participants for alleged manipulative trading activity. The CFTC also issued a related Prediction Markets Advisory reaffirming its oversight authority…

OCC GENIUS Proposal: Three Policy Issues to Watch

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Summary Situation Overview: The Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking (NPR) to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). The NPR addresses…

Vice Chair Bowman Elaborates on Supervisory Priorities and Examination Approach

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Summary Situation Overview: In a recent speech, Vice Chair for Supervision Bowman reiterated the Federal Reserve’s supervisory operating principles and described how the Fed’s supervision should work in practice. What: Firms should…

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…

A New Chapter for Shareholder Proposals: Best Practices for Navigating the 2026 Proxy Season

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Summary Situation Overview: In November 2025, the U.S. Securities & Exchange Commission’s (SEC) Division of Corporation Finance announced that, for the 2025–2026 proxy season, it will no longer issue substantive “no-action” letters…