Insights

Managing AI Risk with Three Lines of Defense: Take the Initiative

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Summary Situation Overview: Anthropic CEO Dario Amodei’s We Must Pace the Frontier memo set off alarm bells for artificial intelligence (AI) safety, but also offered a solution well known to regulated banks: independent embedded evaluators.…

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,…

CFTC Swap Rules for Renewable Energy Transactions: What VPPA Participants Must Know

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Summary Situation Overview: Virtual power purchase agreements (VPPAs) are classified as swaps under the Commodity Exchange Act (CEA). All firms engaging in VPPAs are obligated to comply with certain CFTC regulations, including non-financial…

CFTC Issues No-Action Relief for Swap Data Reporting Error Corrections

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Summary Situation Overview: On December 10, 2025, the Commodity Futures Trading Commission (CFTC) issued no-action relief regarding the correction of errors in swap transaction and pricing data submitted to a swap data repository (SDR). What:…

Patomak Global Partners Named One of the Top Consulting Firms in Fintech by Chambers & Partners

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WASHINGTON D.C. – Patomak Global Partners is honored to share that it has been ranked as one of the top fintech consultancies in the United States for the second consecutive year by Chambers and Partners in the Chambers FinTech Guide 2026.  Each…

SEC’s 2026 SBSD and SBSEF Examination Priorities: What Firms Should Expect and How to Prepare

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Summary Situation Overview: The Securities and Exchange Commission’s (SEC) Division of Examinations (Division) released its 2026 examination priorities for Security-Based Swap Dealers (SBSDs) and, for the first time, examinations for Security-Based…

SBSD De Minimis Threshold Phase-In: Potential Relief Ahead, but Firms Should Prepare for All Scenarios

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Summary Situation Overview: The SEC’s temporary de minimis thresholds for security-based swap dealing activity ($8 billion for credit default swaps and $400 million for non-CDS) are scheduled to change following the expiration of the current…

Spoofing Enforcement Cases and Steps to Protect Your Firm

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Summary Situation Overview: Domestic and foreign regulators continue to pursue actions against firms for spoofing and market manipulation activities. What: There is a continuing need for vigilance in detecting and preventing spoofing, particularly…

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,…