Agencies Jointly Remove Additional References to Reputation Risk
On June 2, 2026, the Federal Deposit Insurance Corporation (FDIC), Federal Reserve Board (FRB), and Office of the Comptroller of the Currency (OCC) have jointly updated interagency documents to remove references to reputation risk. The action was taken to complement earlier actions by the agencies which ended the use of reputation risk in accordance with Executive Order 14331. The agencies continue to review their supervisory materials and may update additional documents as appropriate.
FDIC Board Approves Proposal to Address Bank Secrecy Act and Sanctions Compliance Standards for FDIC-Supervised Permitted Payment Stablecoin Issuers
On May 22, 2026, the FDIC Board of Directors approved a notice of proposed rulemaking that would implement Bank Secrecy Act (BSA) and sanctions compliance standards applicable to FDIC-supervised permitted payment stablecoin issuers (PPSIs) as required by the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act).
Specifically, the proposed rule would require FDIC-supervised PPSIs to comply with applicable regulations regarding anti-money laundering/countering the financing of terrorism (AML/CFT) and economic sanctions programs, and reporting requirements, including requirements established by the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control. The proposed rule would also establish and align supervision and enforcement provisions for PPSI AML/CFT programs with FinCEN requirements.
Comments on the proposed rule will be accepted for 60 days after publication in the Federal Register.
Agencies Jointly Finalize Changes to Community Bank Leverage Ratio
On April 23, 2026, the FDIC, FRB, and OCC jointly finalized a rule to modify the community bank leverage ratio consistent with existing statutory authority. This change will provide community banks with greater flexibility to use a simpler measure of capital adequacy and reduce regulatory burden. The final rule takes into account the unique business models and risk profiles of community banks.
The final rule is being adopted without change from the proposal issued in November 2025. The rule will lower the community bank leverage ratio from 9 percent to 8 percent, which will provide more flexibility for community banks to opt into the framework. The final rule also extends the grace period from two quarters to four quarters for a community bank that temporarily falls out of compliance. The framework continues to simplify regulatory capital requirements for community banks by allowing them to adopt a relatively simple leverage ratio to measure capital adequacy, rather than calculating and reporting risk-based capital ratios.
Community banks that opt into the framework will be subject to a capital requirement that continues to promote safety and soundness. Under the framework, banks must maintain a leverage ratio that is significantly higher than the leverage ratio standard otherwise applicable to community banks.
The changes will take effect on July 1, 2026.
Agencies Issue Revised Model Risk Guidance
On April 17, 2026, The FDIC, FRB, and OCC issued revised model risk management guidance.
The revised guidance clarifies that model risk management should be tailored commensurately to the size, complexity, and model risk profile of a banking organization. To support banking organizations’ model risk management practices, the revised guidance highlights sound principles for effective model risk management—in particular, by discussing the factors that influence model risk and the features of effective model development and model use; model validation and monitoring; and governance and controls. The revised guidance also discusses considerations specific to vendor and other third-party products, including validation of these products. The guidance does not set forth enforceable standards or prescriptive requirements, and non-compliance will not result in supervisory criticism.
Agencies Issue Final Rule to Prohibit Use of Reputation Risk by Regulators
On April 7, 2026, The FDIC and OCC jointly issued a final rule that codifies the elimination of reputation risk from their supervisory programs.
The rule defines “reputation risk” and prohibits the agencies from criticizing or taking adverse action against an institution on the basis of reputation risk. The rule also prohibits the agencies from requiring, instructing, or encouraging an institution to close customer accounts or take other actions on the basis of a person or entity’s political, social, cultural, or religious views or beliefs, constitutionally protected speech, or solely on the basis of politically disfavored but lawful business activities perceived to present reputation risk.
This rule also responds to concerns expressed in Executive Order 14331, Guaranteeing Fair Banking for All Americans, that the use of reputation risk can be a pretext for restricting law-abiding individuals’ and businesses’ access to financial services on the basis of political or religious beliefs or lawful business activities.
FDIC Approves Proposal to Implement GENIUS Act Requirements and Standards
On April 7, 2026, the FDIC Board of Directors approved a notice of proposed rulemaking that would implement certain requirements and standards under the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). The proposed rule would establish a prudential framework for FDIC-supervised permitted payment stablecoins issuers, including requirements related to reserve assets, redemption, capital, and risk management standards.
The proposed rule would also establish requirements for FDIC-supervised permitted payment stablecoin issuers and insured depository institutions (IDIs) that provide certain payment stablecoin related custodial and safekeeping services. In addition, the proposed rule would address the applicability of pass-through insurance to deposits held as reserves backing payment stablecoins and would clarify that tokenized deposits that satisfy the statutory definition of “deposit” would be treated no differently under the Federal Deposit Insurance Act than any other types of deposits.
Comments on the proposed rule will be accepted for 60 days after publication in the Federal Register.
Agencies Request Comment on Anti-Money Laundering/Countering the Financing of Terrorism Proposed Rule
On April 7, 2026, the FDIC, OCC, and National Credit Union Administration (NCUA) jointly invited public comment on a proposed rule to amend the respective requirements for their supervised institutions to establish and maintain effective risk-based AML/CFT programs designed to identify, assess, and mitigate risks of illicit finance. The amendments are intended to align each agency’s AML/CFT rules with changes concurrently proposed by the U.S. Department of the Treasury’s FinCEN.
The Bank Secrecy Act (BSA) refers to the statutory framework imposing various AML/CFT regulatory requirements on financial institutions, including banks and credit unions supervised by the Agencies. In 2020, Congress passed the Anti-Money Laundering Act of 2020 (AML Act), which directed FinCEN and the Agencies to modernize and strengthen the AML/CFT regulatory framework to encourage more effective outcomes for financial institutions, regulators, law enforcement, and national security agencies. The Agencies are proposing to revise their respective regulations to reflect these broader revisions to the BSA, as well as to ensure consistency between FinCEN’s and the Agencies’ separately authorized compliance program requirements.
Among other changes, the proposed rule would:
- Incorporate the AML Act provision that a bank’s AML/CFT program should be risk-based, including ensuring that banks direct more attention and resources toward higher-risk customers and activities, consistent with the risk profile of the institution, rather than toward lower-risk customers and activities.
- Describe the requirements for a bank to establish an AML/CFT program; explicitly incorporate FinCEN’s existing customer due diligence requirement; and clarify that a bank’s designated AML/CFT officer must be located in the U.S. and accessible to regulators.
- Require that once a bank has properly established its AML/CFT program, the institution maintains that program in all material respects. In addition, the proposed rule would clarify that only significant or systemic failures to implement a properly established program would warrant an “AML/CFT enforcement action” or a “significant AML/CFT supervisory action.”
- Enhance FinCEN’s role in the Agencies’ supervision and enforcement process by establishing a new consultation framework for certain actions by the Agencies.
- Clarify that banks may share any information with FinCEN related to certain AML/CFT supervisory and enforcement actions.
Comments on the proposed rule are due 60 days after the date of publication in the Federal Register.
OCC Issues Two Final Rules on Preemption of State Interest-on-Escrow Laws
On May 15, 2026, the OCC issued two final rules on national banks’ and federal savings associations’ real estate lending powers related to the payment of interest on funds held in escrow accounts.
The OCC is codifying longstanding powers of national banks and federal savings associations to establish or maintain real estate lending escrow accounts and to exercise flexibility in making business judgments as to the terms and conditions of such accounts, including whether and to what extent to offer any compensation paid to customers or to assess any related fees. Codifying these longstanding powers provides clarity and reduces uncertainty with regards to bank escrow practices and may thereby incentivize increased bank real estate lending. This final rule is being adopted without changes to the proposed regulatory text.
Second, the OCC is issuing a preemption determination concluding that federal law preempts state laws that restrict national banks’ and federal savings associations’ flexibility to decide whether and to what extent to (1) pay interest or other compensation on funds placed in real estate escrow accounts; or (2) assess fees in connection with such accounts. Specifically, the preemption determination concludes that federal law preempts a New York interest-on-escrow law; 13 other states and territories have laws with substantively equivalent terms; and these substantively equivalent laws are also preempted. The final preemption determination added the interest-on-escrow laws of two U.S. territories—Guam and the U.S. Virgin Islands—but contains no other material changes.
Agencies Announce Final Rule that Establishes Data Standards for Certain Information Collections
On June 11, 2026, the OCC, FRB, FDIC, NCUA, Consumer Financial Protection Bureau (CFPB), Federal Housing Finance Agency (FHFA), Commodity Futures Trading Commission (CFTC), Securities and Exchange Commission (SEC), and Treasury announced a joint final rule that establishes data standards for certain information collections submitted to financial regulatory agencies.
The standards are designed to promote interoperability of financial regulatory data across agencies by establishing data standards for identifiers of legal entities and other data elements. The final rule is generally similar to the proposal from August 2024, with changes reflecting feedback received from the public. It is part of the implementation of the Financial Data Transparency Act of 2022.
Federal Financial Institutions Examination Council (FFIEC) Requests Comment on Financial Institutions Rating System
On May 19, 2026, the FFIEC invited public comment on proposed revisions to the uniform financial institutions rating system, commonly known as CAMELS, to focus on material financial risk and improve the transparency of ratings. The public is encouraged to submit comments within 90 days of publication in the Federal Register.
The proposal would strengthen the link between ratings and a financial institution’s safety and soundness by focusing ratings on material financial risks. The proposal would retain the basic framework of the existing rating system, with certain modifications to the composite and component rating definitions and evaluation factors.
FRB invites public comment on proposal that would allow U.S. banks and credit unions to use intermediaries to transfer funds through the FedNow Service
On April 8, 2026, the FRB invited public comment on a proposal that would allow U.S. banks and credit unions to use intermediaries to transfer funds through the FedNow Service.
This additional flexibility would support new private sector use cases for the FedNow Service. For example, it would allow U.S. banks to use FedNow to transact with correspondent banks to facilitate the international portion of a cross-border payment. Currently, a transfer of funds sent through the FedNow Service can include only two U.S. banks.
Comments are due within 60 days after publication in the Federal Register.
NCUA Board Approves Final Rule on Vital Records Preservation
On June 15, 2026, the NCUA issued a final rule revising record preservation requirements for credit unions in the event of a catastrophic act. This rule is codified at 12 CFR 749.
The final rule will clarify the purpose of the regulation, remove Appendices A and B, and update certain definitions used in the rule. The final rule was adopted largely as proposed but with two changes based on the feedback received from commenters. First, the Board agreed that credit unions should have more flexibility in determining the content of the vital records preservation log rather than adhere to a prescriptive list of factors. Second, the Board determined not to include any reference to consulting with legal counsel on record retention periods in response to commenter feedback.
The final rule is effective 30 days from the date of publication in the Federal Register and takes into consideration public comments received from the proposed rule that was published on March 11, 2026.
NCUA Clarifies Federal Credit Unions’ Power
On June 8, 2026, the NCUA published an interim final rule to clarify federal credit unions’ (FCUs) power to charge non-interest charges and fees, including interchange fees, under the Federal Credit Union Act. NCUA has exclusive authority over FCUs’ ability to charge non-interest charges and fees.
The Interim Final Rule is intended to preempt any state law affecting the non-interest charges and fees related to payment card services. Although NCUA believes that its preemption rules already allow FCUs to impose fees that are set by a third party without state interference, NCUA is adopting this Interim Final Rule both to clarify FCU authority and to avoid any disparity between FCUs and national banks in light of a recently issued interim final rule on the same subject by the Office of the Comptroller of the Currency. As the NCUA’s Interim Final Rule makes clear, state rules regulating FCU activity related to non-interest charges and fees, including interchange fees, are not applicable to FCUs.
The Interim Final Rule takes effect June 30, 2026.
NCUA Board Approves Final Rule on Dependent Care and Board Member Reimbursement
On June 8, 2026, the NCUA issued a final rule for Dependent Care and Board Member Reimbursement.
The NCUA Board amended its regulations concerning the reimbursement of reasonable expenses for federal credit union officials to remove potential barriers to volunteer service. This final rule provides flexibility for a federal credit union’s board to adopt more family-friendly policies tailored to its size, region, and operations. Previously, dependent care costs had not been considered reasonable expenses under NCUA regulation 12 C.F.R. 701.33.
The final rule applies to all federal credit unions, including corporate federal credit unions. It will not apply to federally insured, state-chartered credit unions, which remain subject to state law.
The final rule is effective 30 days from the date of publication in the Federal Register and takes into consideration public comments received from the proposed rule that was issued on January 26, 2026.
NCUA Announces Proposed Rule for Permitted Payment Stablecoin Issuer Standards
On May 15, 2026, the NCUA announced a Notice of Proposed Rulemaking outlining the operational and risk management standards for an NCUA-licensed permitted payment stablecoin issuer, as outlined in the GENIUS Act.
The proposed rule is currently available for review in the Federal Register, where stakeholders will be able to submit comments. The comment period on the proposed rule will close on July 17, 2026.
NCUA Announces Additional Rounds of Deregulation Proposals
The NCUA has announced additional rounds of proposed regulatory changes associated with the NCUA’s deregulation project. The project is an ongoing review of NCUA’s regulations to ensure regulations are focused on credit unions’ safety, soundness, and resilience.
On April 7, 2026, the NCUA announced the ninth round of proposed changes. The proposed rule would remove the automatic disqualification of associational groups that require the purchase of a product or service as a condition of membership. Instead, eligibility will not be automatically denied solely for this reason and more holistic evaluation would be allowed. The proposed amendments would alleviate burden and provide regulatory relief to single associational groups and multiple common bond federal credit unions of all sizes in seeking to include associations that may have some customer-client component.
On April 21, 2026, the NCUA announced the tenth round of proposed changes. The proposed rule would clarify agency guidance and eliminate unduly burdensome and duplicative requirements in the Code of Federal Regulations related to bank conversions and mergers. These changes are intended to allow a credit union’s board of directors to exercise its fiduciary duties and business judgement rather than imposing a rigid, agency-defined process. The proposal includes:
Remove the definition of “clear and conspicuous” from 12 CFR 708a.301 to allow credit unions the flexibility to design disclosures that are effective and clear for their members.
- Revise the newspaper publishing requirement in 12 CFR 708a.303(b)(1) to eliminate an outdated and possibly costly requirement. It would also make pre-board-vote notices more accessible to members who can find that information directly on the homepage of the credit union’s website.
- Revise the due diligence reporting requirements in 12 CFR 708a.304(d) to streamline the reporting requirements, focusing on the substantive outcome of the board’s decision-making process.
- Remove highly prescriptive formatting requirements in 12 CFR 708a.305(e)(2) to reduce administrative burden.
- Remove plain language determining factors in 12 CFR 708a.305(f) to simplify compliance and credit unions would have more flexibility in their merger communications.
- Remove “Voting guidelines” from 12 CFR 708a.312 so that credit unions aren’t confused about what is required.
On May 6, 2026, the NCUA announced the 11th round of proposed changes with two proposed rules.
The first proposed rule would increase the major assets prohibition thresholds to $10 billion for management interlocks required under the Depository Institution Management Interlocks Act (DIMIA). DIMIA has three specific prohibitions, one of which relates to the asset size of the two organizations. This prohibition is intended to capture circumstances in which the two organizations are large enough that the management interlock between them may have an anticompetitive effect, even when the institutions are not in the same community. DIMIA provides that the NCUA may adjust, by regulation, the major assets prohibition thresholds to allow for inflation or market changes. The Board also proposes to remove 12 CFR 711.6(b)(2), which outlines instances in which NCUA would presume that an interlock would not result in a monopoly or substantial lessening of competition for institutions.
The second proposed rule would streamline share insurance regulations. The sections that are proposed for removal primarily refer federally insured state-chartered credit unions (FISCUs) to other NCUA regulations. These proposed changes are intended to reduce duplication.
Updated Questions and Answers Regarding FDIC Official Signs and Advertising Requirements FINANCIAL INSTITUTION LETTER | MAY 15, 2026
Summary:
The Federal Deposit Insurance Corporation (FDIC) is updating its Questions and Answers (Q&As) related to the FDIC’s regulation governing FDIC Official Signs, Advertisement of Membership, False Advertising, Misrepresentation of Insured Status, and Misuse of the FDIC Name or Logo, to reflect the FDIC’s 2026 amendments to the rule (part 328). The Q&As provide answers to a collection of questions from stakeholders, including insured depository institutions (IDIs), trade associations, technology companies, vendors, and other entities, and are intended to promote transparency and support implementation efforts.
The Q&As can be found on the FDIC’s website.
FDIC Rescinds Supervisory Guidance on Multiple Re-Presentment NSF Fees FINANCIAL INSTITUTION LETTER | APRIL 10, 2026
Summary:
On June 16, 2023, the FDIC issued a Financial Institution Letter (FIL-32-2023) titled FDIC Clarifying Supervisory Approach Regarding Supervisory Guidance on Multiple Re-Presentment NSF Fees. This guidance described the FDIC’s supervisory approach relating to supervised institutions assessing multiple non-sufficient funds (NSF) fees arising from the re-presentment of the same unpaid transaction. The FDIC is rescinding FIL-32-2023 effective immediately.
