The Federal Reserve Board and the Federal Deposit Insurance Corporation have issued substantially identical notices of proposed rulemaking to modernize the regulations governing extensions of credit by banks to their executive officers, directors, principal shareholders, and their related interests. Because the agencies supervise different categories of insured depository institutions, each is proposing amendments to its own regulations, although the proposals are virtually identical in substance.… Continue Reading
Federal Reserve Board
Federal Banking Agencies Adopt Coordinated Approach to Protect Highly Sensitive Information During Bank Examinations
The federal banking agencies, the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency, have issued a joint statement establishing a coordinated approach for the handling of highly sensitive information during bank examinations. While the statement does not impose new supervisory expectations, it represents an important acknowledgment that the examination process itself can create cybersecurity and information security risks if highly sensitive information is not handled appropriately.… Continue Reading
GAO Report Reinforces Trump Administration’s Regulatory Reform Agenda for the Banking Industry
The U.S. Government Accountability Office (GAO) recently issued a report recommending that the federal banking agencies adopt a more rigorous and transparent process for identifying and eliminating outdated, unnecessary, or unduly burdensome banking regulations. Although the report focuses on improving the agencies’ review process rather than recommending the repeal of any specific regulations, its conclusions align closely with the Trump Administration’s broader effort to reduce regulatory burdens throughout the federal government.… Continue Reading
Supreme Court Overrules Humphrey’s Executor, Vastly Expands Presidential Removal Authority—But Preserves Federal Reserve Independence
In a pair of very important decisions issued today, the U.S. Supreme Court reshaped the constitutional landscape governing independent federal agencies. In Trump v. Slaughter, Court overruled the 91-year-old precedent of Humphrey’s Executor v. United States, 295 U.S. 602( 1935), and held that members of the Federal Trade Commission may be removed by the President at will, notwithstanding statutory “for cause” removal protections.… Continue Reading
Banking agencies update interagency documents to remove reputational risk references
The Federal Reserve Board, FDIC and OCC have jointly updated interagency documents to delete references to reputational risk.
The agencies took this action to complement their earlier actions to end the use of reputational risk in supervision.
“As the agencies have previously noted, reputation risk can be misused by supervisors as a basis to encourage or pressure a bank to restrict individuals’ and legal businesses’ access to financial services due to their constitutionally protected political or religious beliefs, speech, or conduct or lawful business activities,” the agencies said, in a joint statement.… Continue Reading
CAMELS Reform Arrives: Federal Regulators Propose Sweeping Supervisory Changes
The federal banking agencies have proposed on May 19, 2026 the most significant overhaul of the CAMELS supervisory rating system in nearly 30 years, signaling a major philosophical shift in bank supervision under the Trump Administration. The proposal, issued by the Federal Financial Institutions Examination Council (“FFIEC”), would revise the Uniform Financial Institutions Rating System (“UFIRS”) to place greater emphasis on material financial risks and less emphasis on process-oriented supervisory criticisms.… Continue Reading
Warsh to be sworn in as Fed Chair on May 22
Kevin Warsh will be sworn in as the new Chairman of the Federal Reserve Board on May 22. He replaces Jerome Powell.
Warsh was confirmed on a 55-45 roll call vote on May 13. All Republicans and one Democrat, Sen. John Fetterman, D-Pa. voted in favor of the nomination. Sen. Kirsten Gillibrand, D-N.Y.,… Continue Reading
Fed requests comment on plan to remove reputation risk from supervision of banks
The Federal Reserve is requesting comments on a proposal to remove reputation risk from the supervision of banks it oversees. Comments on the Fed proposal are due April 27, 2026.
“We have heard troubling cases of debanking—where supervisors use concerns about reputation risk to pressure financial institutions to debank customers because of their political views, religious beliefs, or involvement in disfavored but lawful businesses,” Vice Chair for Supervision Michelle W.… Continue Reading
Supreme Court Hears Arguments Regarding President Trump’s Attempt to Remove Lisa Cook from the Fed Board of Governors
The U.S. Supreme Court recently heard oral arguments in Trump v. Cook, involving the issue of whether the President may remove Lisa Cook as a member of the Board of Governors of the Federal Reserve Board. Board Members may be removed “for cause,” and the President has cited alleged mortgage fraud as the basis for the removal of Cook as a Board Member.… Continue Reading
CFPB Funding Issues Seem to be Coming to a Head
As we have previously reported, a lawsuit was brought early this year by the unions representing CFPB employees against Acting CFPB Director Vought and the CFPB in the DC District Court.
The Court months ago enjoined the CFPB from terminating some 1,400 employees and taking certain other actions in pursuit of Vought’s goal of minimizing the CFPB while the lawsuit is pending.… Continue Reading