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Cabinet News - Research and commentary on regulatory and other financial services topics. Cabinet News - Research and commentary on regulatory and other financial services topics. Cabinet News - Research and commentary on regulatory and other financial services topics.
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Profile photo of contributor Daniel Meade
Partner | Financial Regulation

On April 7, the Federal Deposit Insurance Corporation (“FDIC”) and the Office of the Comptroller of the Currency (“OCC”) approved a final rule that prohibits regulators from using "reputation risk" as a standalone basis for supervisory or enforcement actions. This final rule is adopted largely as proposed in October. 

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Profile photo of contributor Daniel Meade
Partner | Financial Regulation
Profile photo of contributor Christopher Horn
Partner | Financial Services

On March 19, 2026, the Federal Reserve Board ("FRB"), Office of the Comptroller of the Currency (“OCC”) and Federal Deposit Insurance Corporation (“FDIC”, collectively, the “Agencies”) released (i) a revised proposal for Basel III Endgame applicable to Category I and II institutions (the “ERBA Proposal”) and (ii) proposed amendments to the existing standardized approach capital rules (the “Standardized Proposal”). 

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Profile photo of contributor Daniel Meade
Partner | Financial Regulation

In remarks delivered at the American Bankers Association’s Washington Summit on March 11, 2026, FDIC Chairman Travis Hill outlined the agency’s ongoing effort to recalibrate the federal banking regulators’ supervisory and regulatory “toolkit.”

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Profile photo of contributor Mercedes Kelley Tunstall
Partner | Financial Regulation
Profile photo of contributor Daniel Meade
Partner | Financial Regulation
Profile photo of contributor Christina Mille
Associate | Financial Services

On March 11, 2026, the Securities and Exchange Commission (“SEC”) and Commodity Futures Trading Commission (“CFTC”) announced that they have entered into a new Memorandum of Understanding (“MOU”) to coordinate rulemaking, supervision, examinations and enforcement across areas where the agencies’ jurisdiction overlaps.

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Profile photo of contributor Daniel Meade
Partner | Financial Regulation

In opening remarks at the Federal Reserve Bank of Atlanta’s 2026 Banking Outlook Conference, Federal Reserve Vice Chair for Supervision Michelle Bowman outlined what she described as “the next horizon in banking” — a supervisory and regulatory agenda centered on clearer tailoring, capital recalibration, and a more disciplined focus on material financial risk. Vice Chair Bowman tied together three threads that have appeared across her prior speeches — tailoring, transparency, and pragmatism — and translated them into near-term supervisory and capital priorities.

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Profile photo of contributor Daniel Meade
Partner | Financial Regulation
Profile photo of contributor Mercedes Kelley Tunstall
Partner | Financial Regulation
Profile photo of contributor Christina Mille
Associate | Financial Services

On February 25, 2026, the Office of the Comptroller of the Currency (the “OCC”) issued a Notice of Proposed Rulemaking (the “NPRM”) to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act”). The proposal would add a new Part 15 to the OCC’s regulations and establish the supervisory framework applicable to “permitted payment stablecoin issuers” subject to OCC jurisdiction. The comment period will run for sixty days after publication in the Federal Register. 

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Profile photo of contributor Daniel Meade
Partner | Financial Regulation
Profile photo of contributor Christopher Horn
Partner | Financial Services

In remarks delivered on January 16, 2026, to the American Bar Association Banking Law Committee meeting in Washington, DC, Comptroller of the Currency Jonathan Gould offered a strong critique of the current U.S. bank resolution planning framework, questioning both its legal foundations and its practical value after more than a decade of implementation.

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Profile photo of contributor Mercedes Kelley Tunstall
Partner | Financial Regulation
Profile photo of contributor Daniel Meade
Partner | Financial Regulation

On December 19, 2025, the Federal Reserve Board issued a Request for Information (“RFI”) on a proposed “Payment Account prototype.” The proposal responds to growing pressure from payments-focused institutions — particularly uninsured and novel charter entities — seeking faster, more predictable access to Federal Reserve payment rails that currently are only available with a Federal Reserve Bank master account.

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Profile photo of contributor Mercedes Kelley Tunstall
Partner | Financial Regulation
Profile photo of contributor Daniel Meade
Partner | Financial Regulation

On December 22, 2025, the Board of Governors of the Federal Reserve (the Board) issued a final rule that rescinded a 2023 policy statement and that in turn issued a new policy statement. In a memo submitted to the Board in November, Board staff explained that the 2023 policy statement was put into place at the time to address “particular sets of facts related to certain crypto-assets” and that the policy was intended to describe how the Board would approach regulating state member banks interested in engaging in such crypto-asset activities.

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Profile photo of contributor Daniel Meade
Partner | Financial Regulation
Profile photo of contributor Christina Mille
Associate | Financial Services

On December 12, 2025, the Office of the Comptroller of the Currency granted the conditional approval of five national trust bank charter applications involving crypto-focused institutions. The approvals include two de novo charters, First National Digital Currency Bank and Ripple National Trust Bank, and the conversion of three state trust companies, BitGo Bank & Trust, Fidelity Digital Assets, and Paxos Trust Company, into uninsured national trust banks subject to OCC supervision.

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