Risk Management Solutions Group

Every two weeks, RMSG produces “The Reg Report.” We compile the most significant regulatory updates in one place to make it easier to keep up with the ever-evolving landscape. Here is an Executive Summary of the current period. • 𝐁𝐚𝐧𝐤 𝐑𝐞𝐠𝐮𝐥𝐚𝐭𝐢𝐨𝐧 𝐁𝐢𝐥𝐥: The House committee advanced H.R. 6955, a community banking bill focused on regulatory relief, de novo formation, and CDFI support. • 𝐂𝐲𝐛𝐞𝐫𝐬𝐞𝐜𝐮𝐫𝐢𝐭𝐲 𝐒𝐭𝐫𝐚𝐭𝐞𝐠𝐲: The White House issued a national cybersecurity strategy and related executive order to strengthen cyber defense, fraud enforcement, and public-private coordination. • 𝐓𝐨𝐤𝐞𝐧𝐢𝐳𝐞𝐝 𝐒𝐞𝐜𝐮𝐫𝐢𝐭𝐢𝐞𝐬: FDIC, FRB, and OCC said eligible tokenized securities generally receive the same capital treatment as traditional securities. • 𝐁𝐒𝐀/𝐀𝐌𝐋 𝐌𝐚𝐧𝐮𝐚𝐥: FFIEC removed reputational risk references from its BSA/AML Examination Manual. • 𝐒𝐨𝐮𝐭𝐡𝐰𝐞𝐬𝐭 𝐁𝐨𝐫𝐝𝐞𝐫 𝐆𝐓𝐎: FinCEN extended and expanded its southwest border GTO for certain MSBs, adding New Mexico counties and continuing enhanced reporting requirements. • 𝐂𝐎𝐏𝐏𝐀 𝐒𝐭𝐚𝐭𝐞𝐦𝐞𝐧𝐭: FTC said it will not bring certain COPPA enforcement actions based solely on age-verification data collection. • 𝐒𝐭𝐚𝐛𝐥𝐞𝐜𝐨𝐢𝐧 𝐂𝐨𝐦𝐦𝐞𝐧𝐭𝐬: ABA and other trade groups asked OCC to extend the comment period on its GENIUS Act stablecoin proposal. • 𝐎𝐂𝐂 𝐁𝐮𝐫𝐝𝐞𝐧 𝐑𝐞𝐥𝐢𝐞𝐟: OCC finalized two rules easing community bank requirements by rescinding Part 27 and simplifying licensing procedures. • 𝐂𝐡𝐚𝐫𝐭𝐞𝐫𝐢𝐧𝐠 𝐑𝐮𝐥𝐞: OCC finalized a rule clarifying that certain national trust banks may conduct related non-fiduciary activities. • 𝐆𝐄𝐍𝐈𝐔𝐒 𝐀𝐜𝐭 𝐏𝐫𝐨𝐩𝐨𝐬𝐚𝐥: OCC proposed a framework for payment stablecoin issuers and certain custody activities under the GENIUS Act. • 𝐍𝐘𝐂 𝐃𝐞𝐛𝐭 𝐂𝐨𝐥𝐥𝐞𝐜𝐭𝐢𝐨𝐧 𝐑𝐮𝐥𝐞: New York City finalized a debt collection rule covering banks collecting their own debts, with requirements beyond federal standards. Link to "The Reg Report": https://lnkd.in/e5gx_mm2

Every two weeks, RMSG produces “The Reg Report”. We compile the most significant regulatory updates in one place to make it easier to keep up with the ever-evolving landscape. Here is an Executive Summary of the current period. • 𝐎𝐂𝐂 𝐀𝐩𝐩𝐞𝐚𝐥𝐬 𝐏𝐫𝐨𝐜𝐞𝐬𝐬: OCC proposed revisions to appeals procedures to improve independence and efficiency. • 𝐋𝐂𝐑 𝐅𝐀𝐐𝐬 𝐑𝐞𝐬𝐜𝐢𝐧𝐝𝐞𝐝: FRB, OCC, and FDIC rescinded LCR FAQs but left them posted; the rule itself remains unchanged. • 𝐏𝐀𝐂𝐄 𝐑𝐮𝐥𝐞 𝐔𝐩𝐡𝐞𝐥𝐝: A federal court upheld CFPB’s PACE rule, affirming PACE financing as “credit” under TILA. • 𝐆𝐀𝐎 𝐂𝐅𝐏𝐁 𝐑𝐞𝐯𝐢𝐞𝐰: GAO detailed CFPB downsizing actions, including enforcement cuts, workforce reductions, and withdrawn guidance. • 𝐑𝐞𝐩𝐮𝐭𝐚𝐭𝐢𝐨𝐧 𝐑𝐢𝐬𝐤 𝐏𝐫𝐨𝐩𝐨𝐬𝐚𝐥: FRB proposed removing “reputation risk” from supervision to focus on material financial risks. • 𝐄𝐆𝐑𝐏𝐑𝐀 𝐎𝐮𝐭𝐫𝐞𝐚𝐜𝐡: FRB will hold a March 26, 2026, meeting seeking input on outdated or burdensome regulations. • 𝐔𝐁𝐏𝐑 𝐏𝐞𝐞𝐫 𝐆𝐫𝐨𝐮𝐩𝐬: FFIEC will update UBPR peer group definitions effective on or after February 26, 2026. •𝐅𝐢𝐧𝐂𝐄𝐍 𝐂𝐃𝐃 𝐑𝐞𝐥𝐢𝐞𝐟: FinCEN eased beneficial ownership verification requirements, limiting re-verification to risk-based triggers while maintaining BSA obligations. • 𝐅𝐢𝐧𝐂𝐄𝐍 𝐖𝐡𝐢𝐬𝐭𝐥𝐞𝐛𝐥𝐨𝐰𝐞𝐫 𝐏𝐨𝐫𝐭𝐚𝐥: FinCEN launched a tips portal offering potential awards for reporting financial crimes. • 𝐇𝐔𝐃 𝐄𝐥𝐢𝐠𝐢𝐛𝐢𝐥𝐢𝐭𝐲 𝐑𝐮𝐥𝐞: HUD proposed requiring citizenship or immigration verification for housing assistance applicants. • 𝐂𝐑𝐀 𝐏𝐥𝐚𝐧𝐧𝐢𝐧𝐠: ABA-backed OCC efforts to simplify CRA strategic planning for community banks. • 𝐀𝐈 𝐂𝐲𝐛𝐞𝐫 𝐈𝐧𝐢𝐭𝐢𝐚𝐭𝐢𝐯𝐞: Treasury concluded an industry initiative issuing resources to strengthen AI cybersecurity and risk management. Link to the "Reg Report": https://lnkd.in/e4Pqufyx

Every two weeks, RMSG produces “The Reg Report". We compile the most significant regulatory updates in one place to make it easier to keep up with the ever-evolving landscape. Here is an Executive Summary of the current period.     • 𝐅𝐃𝐈𝐂 𝐑𝐮𝐥𝐞: FDIC finalized Part 328 amendments on signage and advertising; effective March 2, 2026, compliance by April 1, 2027. • 𝐅𝐑𝐁 𝐍𝐨𝐦𝐢𝐧𝐚𝐭𝐢𝐨𝐧: The White House announced President Trump’s nomination of Kevin Warsh as FRB Chair, succeeding Jerome Powell. • 𝐒𝐜𝐚𝐦 𝐀𝐝𝐬 𝐁𝐢𝐥𝐥: Senators Moreno and Gallego introduced bipartisan legislation targeting fraudulent online ads; ABA supports. • 𝐂𝐅𝐏𝐁 𝐂𝐚𝐬𝐞: Nearly 200 lawmakers urged the D.C. Circuit to halt alleged efforts to dismantle CFPB. • 𝐒𝐭𝐚𝐛𝐥𝐞𝐜𝐨𝐢𝐧𝐬: FDIC extended to May 18, 2026, comments on its GENIUS Act stablecoin proposal. • 𝐌𝐚𝐬𝐭𝐞𝐫 𝐀𝐜𝐜𝐨𝐮𝐧𝐭𝐬: FRB Governor Waller floated a limited “payment account” option for non-bank firms. • 𝐔𝐁𝐏𝐑 𝐂𝐡𝐚𝐧𝐠𝐞𝐬: FFIEC updated UBPR liquidity pages effective on or after February 17, 2026. • 𝐅𝐇𝐅𝐀 𝐑𝐞𝐩𝐞𝐚𝐥: FHFA repealed 12 CFR Part 1293, effective March 8, 2026. Link to the "Reg Report": https://lnkd.in/dhQR4GG6

Every two weeks, RMSG produces “The Reg Report” (attached). We compile the most significant regulatory updates in one place to make it easier to keep up with the ever-evolving landscape. Here is an Executive Summary of the current period.     • 𝐇𝐨𝐮𝐬𝐞 𝐀𝐜𝐭𝐢𝐨𝐧: The House Financial Services Committee advanced three ABA-backed bills on community-bank regulatory tailoring, TRIA reauthorization, and higher CTR and SAR thresholds. • 𝐒𝐞𝐧𝐚𝐭𝐞 𝐏𝐫𝐨𝐩𝐨𝐬𝐚𝐥: Senators Fetterman, Booker, and Baldwin introduced legislation to cap credit card late fees at $8 for large issuers. • 𝐂𝐅𝐏𝐁 𝐅𝐮𝐧𝐝𝐢𝐧𝐠: CFPB received $145 million from the FRB to operate through March 2026. • 𝐇𝐌𝐃𝐀 𝐔𝐩𝐝𝐚𝐭𝐞𝐬: The CFPB will end GovDelivery email alerts for HMDA updates effective January 20, 2026. • 𝐂𝐅𝐏𝐁 𝐑𝐞𝐩𝐨𝐫𝐭: The CFPB released its FY2024 Performance Report outlining shifts under Acting Director Russell Vought. • 𝐅𝐃𝐈𝐂 𝐀𝐩𝐩𝐞𝐚𝐥𝐬: The FDIC created an independent Office of Supervisory Appeals as the final review authority. • 𝐅𝐃𝐈𝐂 𝐒𝐢𝐠𝐧𝐚𝐠𝐞: The FDIC finalized Part 328 signage changes, extending the compliance date to April 1, 2027. • 𝐒𝐭𝐚𝐛𝐥𝐞𝐜𝐨𝐢𝐧𝐬: Banking trade groups asked the FDIC to extend the comment deadline on its proposed GENIUS Act stablecoin rule. Link to "The Reg Report": https://lnkd.in/gW3T4EtJ