Insights

Congress Champions Community Bank Regulatory Relief
Banking & Consumer Finance David Hou, Andrew Grub, Mona Elliot Strategy & AdvisorySummary
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
Banking & Consumer Finance Ray Strecker, Heather Espinosa Risk Management & ComplianceSummary
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
Banking & Consumer Finance Andrew Grub, Heather Espinosa Risk Management & ComplianceSummary
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
Securities Michael Kress, Cory Jack, Laura Magyar Risk Management & ComplianceSummary
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…

Understanding Regulatory Attention on Private Assets and AI Across Capital Markets and Insurance
Banking & Consumer Finance Andrew Grub, Mona Elliot Risk Management & Compliance, Strategy & AdvisorySummary
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
Banking & Consumer Finance, Digital Assets Diane Daley, Heather Espinosa Risk Management & ComplianceSummary
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
Securities Cory Jack, Laura Magyar Risk Management & ComplianceSummary
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…

CFTC Chair Outlines Priorities for Prediction Markets and Digital Asset Market Structure
Derivatives, Digital Assets Sam Canavos, Sudhir Jain Risk Management & Compliance, Strategy & AdvisorySummary
Situation Overview: On January 29, Commodity Futures Trading Commission Chair Michael Selig made his first public remarks at the CFTC-SEC harmonization event. Among other things, Chairman Selig laid out the agency’s priorities, which…

Resolution Planning Faces Regulatory Uncertainty
Banking & Consumer Finance Diane Daley, Heather Espinosa Risk Management & ComplianceSummary
Situation Overview: A U.S. bank regulator signaled potential relaxation of resolution planning requirements for banks, while the Financial Stability Board (FSB) reiterated its support and focus on enhancing resolution planning capabilities.
What:…

Fed Withdrawal of Guidance Marks Milestone for Banks’ Future Crypto Activity
Banking & Consumer Finance, Digital Assets, Securities, Patomak Analysis Sam Canavos, Mona Elliot Strategy & AdvisorySummary:
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
Banking & Consumer Finance, Patomak Analysis Heather EspinosaSummary:
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…

Banking Regulators Send Strong Warning About Crypto Risks
Banking & Consumer Finance Chris Beckmann, Bryan Hubbard, Keith Noreika
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…

