PH FedACTion: Financial Regulatory Updates
Daily Financial Regulation Update -- Monday, December 22, 2025
December 22, 2025
Edited by Lawrence D. Kaplan, Jason Shafer and Kris Knabe
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Major Developments
Consumer Financial Protection Bureau
December 22, 2025
CFPB Issues Advisory Opinion on Earned Wage Access Products and Regulation Z Compliance
The Consumer Financial Protection Bureau (CFPB) issued an advisory opinion to resolve regulatory uncertainty regarding:
(1) The applicability of the definition of credit under Regulation Z, which implements the Truth in Lending Act (TILA), to certain covered earned wage access (EWA) products.
(2) The applicability of the definition of finance charge under Regulation Z to certain EWA-related charges (including expedited delivery fees, tips) to the extent any EWA products meet the Regulation Z definition of credit.
Federal Reserve Board
Federal Reserve Board Requests Public Input on ‘Skinny Master Accounts’
December 19, 2025
The Federal Reserve Board requested public input on a payment account that eligible financial institutions could use for the limited purpose of clearing and settling their payments.
Federal Agencies
Federal Reserve Board
Federal Reserve Board Publishes Biennial Report on Debit Card Transactions
December 19, 2025
The Federal Reserve Board published its biennial report on debit card transactions, which summarizes information collected from large debit card issuers and payment card networks.
Working Paper: ‘HANK Comes of Age: Monetary Policy with Heterogeneous Overlapping Generations’
December 19, 2025
The Federal Reserve Board published a working paper titled “HANK Comes of Age: Monetary Policy with Heterogeneous Overlapping Generations.”
Federal Reserve Bank of New York
Report: ‘How Do Banks Build Equity Capital?’
December 19, 2025
The Federal Reserve Bank of New York published a staff report titled “How Do Banks Build Equity Capital?”
Speech: ‘The U.S. Economy: Reflections and a Look Ahead’
December 19, 2025
Federal Reserve Bank of New York Director of Research Kartik Arthreya gave a speech titled “The U.S. Economy: Reflections and a Look Ahead.”
Office of the Comptroller of the Currency
OCC Reports Q3 2025 Bank Trading Revenue
December 19, 2025
The Office of the Comptroller of the Currency reported cumulative trading revenue of U.S. commercial banks and savings associations of $18.4 billion in Q3 2025.
Securities and Exchange Commission
SEC Chief Accountant Delivers Remarks at 2025 AICPA Conference on Current SEC and PCAOB Developments
December 19, 2025
Securities and Exchange Commission Chief Accountant Kurt Hohl issued a statement in connection with the 2025 AICPA Conference on Current SEC and PCAOB Developments.
Commodity Futures Trading Commission
CFTC Announces Pilot Program to Unleash American Energy Dominance
December 19, 2025
The Commodity Futures Trading Commission (CFTC) announced that the Market Participants Division has established a pilot program designed to increase liquidity and hedging of risks in connection with Energy Commodity End User Swaps.
CFTC Staff Issues No-Action Letter Regarding CPO Registration for Certain SEC-Registered Investment Advisers
December 19, 2025
The CFTC’s Market Participants Division announced it has issued a no-action letter addressing CPO Registration for Registered Investment Advisors to the Managed Funds Association, which submitted the request on behalf of its members.
Statement on IOSCO Pre-Hedging Report
December 19, 2025
CFTC Acting Chair Caroline D. Pham issued a statement on the IOSCO’s final report on prehedging.
Financial Crimes Enforcement Network
Treasury Convenes Financial Institutions and Law Enforcement to Identify and Dismantle Money Laundering Networks
December 19, 2025
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) held a FinCEN Exchange, a public-private partnership event aimed at countering illicit finance.
International
European Commission
Commission Welcomes Agreement on Retail investment Strategy
December 19, 2025
The European Commission welcomes the political agreement reached yesterday between the European Parliament and EU Member States on the Retail Investment Strategy.
European Banking Authority
Bank of England
Working Paper: ‘Geopolitical risk and cross-border bank lending’
December 19, 2025
The Bank of England published a staff working paper titled “Geopolitical risk and cross-border bank lending.”
Working Paper: ‘EcoFinBench – a natural language processing benchmark for economics and finance’
December 19, 2025
The Bank of England published a staff working paper titled “EcoFinBench – a natural language processing benchmark for economics and finance.”
Minutes of the Money Market Committee Meeting — December 2025
December 19, 2025
The Bank of England released the minutes of the Money Market Committee meeting held Dec. 10.
Market Participants Survey Results — December 2025
December 19, 2025
The Bank of England released the Market Participants Survey results for December 2025.
Consolidated Worldwide Claims — Q3 2025
December 19, 2025
The Bank of England released the consolidated worldwide claim statistics for Q3 2025.
Banking Sector Regulatory Capital — Q3 2025
December 19, 2025
The Bank of England released the banking sector regulatory capital for Q3 2025.
Bank of England Prudential Regulation Authority
Low Impact Amendments Finalization — December 2025
December 19, 2025
The Prudential Regulation Authority published a collection of final low impact rule amendments.
Financial Conduct Authority
FCA Gives Banks and Payment Providers Greater Flexibility to Set Future Contactless Limits
December 19, 2025
The Financial Conduct Authority released a notice setting out greater flexibility and removing red tape for using contactless payment.
Administration Changes
Vacancies
Appointments
U.S. Department of the Treasury – Scott Bessent (effective January 27, 2025)
Federal Reserve Board – Jerome H. Powell (effective May 23, 2022)
- Vice Chair Phillip N. Jefferson (sworn in September 13, 2023)
- Vice Chair for Supervision Michelle W. Bowman (sworn in June 9, 2025)
- Governor Michael Barr (sworn in July 19, 2022)
- Governor Christopher J. Waller (sworn in December 18, 2020)
- Governor Lisa D. Cook (sworn in September 13, 2022 – SCOTUS hearing on purported termination to be held in January 2026)
- Stephen Miran (sworn in September 16, 2025)
Federal Reserve Bank of New York – John C. Williams (effective June 18, 2018)
Federal Reserve Bank of Boston – Susan M. Collins (effective July 1, 2022)
Federal Deposit Insurance Corporation – Travis Hill (Acting Chairman effective January 20, 2025, nominated to be Chair September 30, 2025 and Confirmed December 18, 2025)
- Vice Chairman Vacant
- Director Vacant
- Director Jonathan Gould (Comptroller of the Currency)
- Director Russel Vought (Director of Consumer Financial Protection Bureau)
Office of the Comptroller of the Currency – Jonathan Gould (effective July 15, 2025)
Securities and Exchange Commission – Paul Atkins (effective April 9, 2025)
Commodity Futures Trading Commission – Michael Selig (confirmed December 18, 2025)
Consumer Financial Protection Bureau – Russel Vought (Acting Director effective February 10, 2025)
National Credit Union Administration – Kyle Hauptman (Chairman effective January 20, 2025)
Small Business Administration – Kelly Loeffler (effective February 19, 2025)
U.S. Department of Housing and Urban Development – Scott Turner (effective February 5, 2025)
Federal Housing Finance Agency – William Pulte (effective March 13, 2025)
U.S. Department of Education – Linda McMahon (effective March 3, 2025)
Financial Crimes Enforcement Network – Andrea Gacki (effective July 13, 2023)
PH Client Alerts
Click here to read more from our Coronavirus series.
Legislation/Legislative Updates
Click here to view the full text of the Coronavirus Aid, Relief and Economic Security Act (the “CARES Act”), enacted March 27, 2020.
Click here to view the full text of the Paycheck Protection Program Increase Act of 2020, enacted April 24, 2020.
Click here to view the full text of the Paycheck Protection Program Flexibility Act of 2020, enacted June 5, 2020.
Click here to view the full text of theConsolidated Appropriations Act, 2021, enacted December 27, 2020.
Click here to view the full text of the American Rescue Plan of 2021, enacted March 11, 2021.
Click here to view the full text of the PPP Extension Act of 2021, enacted March 30, 2021.
Click here to view a running list of proposed legislation from the Senate Committee on Banking, Housing and Urban Affairs, Senate Committee on Small Business and Entrepreneurship, House Committee on Financial Services and House Committee on Small Business
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