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PH FedACTion: Financial Regulatory Updates

Daily Financial Regulation Update -- Wednesday, December 17, 2025

December 17, 2025

Edited by Lawrence D. Kaplan, Jason Shafer and Kris Knabe

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Major Developments

Federal Deposit Insurance Corporation

FDIC Proposes GENIUS Act Application Procedures for FDIC-Supervised Institutions Seeking to Issue Payment Stablecoins

December 16, 2025

The Federal Deposit Insurance Corporation’s Board of Directors approved a notice of proposed rulemaking that, when effective, would implement the application provisions under the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). 

 

Congress

U.S. Senate

Senators Introduce Bipartisan Bill to Strengthen and Sustain Pressure on Russian Oil Revenue

December 16, 2025

U.S. Sens. Dave McCormick (R-PA), Elizabeth Warren (D-MA), Chris Coons (D-DE) and Jon Husted (R-OH) introduced the Decreasing Russia Oil Profits (DROP) Act of 2025 requiring targeted sanctions on those dealing in Russian oil.

 

Lawmakers File Amicus Brief Challenging Efforts to Withhold Funding From CFPB

December 16, 2025

Ranking member of the Senate Banking, Housing and Urban Affairs Committee Elizabeth Warren (D-MA), ranking member of the House Financial Services Committee Maxine Waters (D-CA), and former lawmakers Chris Dodd (D-CT) and Barney Frank (D-MA), authors of the Dodd-Frank Act, filed an amicus brief challenging Consumer Financial Protection Bureau (CFPB) Acting Director Russell Vought’s attempt to dismantle the agency by denying it the funds it needs to operate.

 

U.S. House of Representatives

Committee on Small Business

Hearing: ‘American Resilience: Examining the SBA Disaster Assistance Program’

December 16, 2025

The U.S. House Committee on Small Business held a hearing titled “American Resilience: Examining the SBA Disaster Assistance Program.”

 

Federal Agencies

Federal Reserve Board

Working Paper: ‘Dollarization Waves: New Evidence from a Comprehensive International Bond Database’

December 16, 2025

The Federal Reserve Board published a working paper titled “Dollarization Waves: New Evidence from a Comprehensive International Bond Database.”

 

OIG Report: ‘The Board's Contract Solicitation, Selection, and Award Processes for the Contracts We Reviewed Were Generally Effective but Can Be Further Enhanced’

December 16, 2025

The Office of Inspector General of the Federal Reserve Board issued a report titled “The Board's Contract Solicitation, Selection, and Award Processes for the Contracts We Reviewed Were Generally Effective but Can Be Further Enhanced.”

 

Federal Reserve Bank of New York

Business Leaders Survey — December 2025

December 16, 2025

The Federal Reserve Bank of New York released the Business Leaders Survey for December 2025.

 

Federal Deposit Insurance Corporation

FDIC Issues Interim Final Rule to Amend Collection of the Special Assessment

December 16, 2025

The Federal Deposit Insurance Corporation (FDIC) Board of Directors approved an interim final rule to amend the collection of the special assessment to recover losses to the Deposit Insurance Fund (DIF) arising from the systemic risk determination announced on March 12, 2023, following the closures of Silicon Valley Bank and Signature Bank, as required by the Federal Deposit Insurance Act.

 

FDIC Approves Final Rule on Establishment and Relocation of Branches and Offices

December 16, 2025

The FDIC Board of Directors approved a final rule to streamline the processes for the establishment and relocation of domestic branches and main offices.

 

FDIC Approves 2026 Operating Budget

December 16, 2025

The FDIC Board of Directors approved a 2026 budget of $2.49 billion to support the agency’s ongoing operations and receivership functions. 

 

Office of the Comptroller of the Currency

OCC Semiannual Risk Perspective Highlights Key Risks in Federal Banking System

December 16, 2025

The Office of the Comptroller of the Currency (OCC) reported the key issues facing the federal banking system in the Semiannual Risk Perspective for Fall 2025.

 

OCC Reports Mortgage Performance for Q3 2025

December 16, 2025

The OCC reported on the performance of first-lien mortgages in the federal banking system during Q3 2025.

 

Securities and Exchange Commission

Roundtable on Rule 611 of Regulation NMS

December 16, 2025

The Securities and Exchange Commission hosted a roundtable to discuss Rule 611 of Regulation NMS and other associated rules and regulatory requirements.

 

U.S. Department of Labor

BLS Releases November Jobs Report

December 16, 2025

The Bureau of Labor Statistics released the Employment Situation Report for November 2025.

 

Department of Labor, IRS and Pension Benefit Guaranty Corp. Release Information for 2025 Annual Benefits Plan Report and Return Filings

December 16, 2025

The U.S. Department of Labor announced that its Employee Benefits Security Administration joined the Internal Revenue Service and Pension Benefit Guaranty Corp. in releasing informational copies of the 2025 Form 5500, Form 5500-SF, IRS Form 5500-EZ, IRS Form 5558 and related instructions online.

 

State Agencies

New York State Department of Financial Services

Statement by DFS Acting Superintendent on Use of Artificial Intelligence Systems in Insurance Underwriting and Pricing

December 16, 2025

New York State Department of Financial Services Acting Superintendent Kailin Asrow gave remarks at the NYS Assembly hearing on the use of artificial intelligence systems in insurance underwriting and pricing.

 

International

European Banking Authority

The EBA Publishes Final Draft Technical Standards on Threshold for CSDs Providing Banking-Type Ancillary Services

December 16, 2025

The European Banking Authority (EBA) published its final draft Regulatory Technical Standards (RTS) establishing the threshold up to which non-banking central securities depositories (CSDs) may use banking CSDs or credit institutions for cash settlement without entities needing additional authorization.

 

Financial Conduct Authority

Engagement Paper: ‘Bespoke market risk rules could unlock growth’

December 16, 2025

The Financial Conduct Authority (FCA) is seeking feedback on whether tailored market risk rules for non-bank trading firms could remove unnecessary barriers, free up capital and attract new market participants, ultimately supporting economic growth.

 

FCA Seeks Feedback on Proposals for UK Crypto Rules

December 16, 2025

The FCA is seeking feedback on crypto proposals related to the following:

 

FCA Publishes Figures on Open Banking

December 16, 2025

The FCA released industry figures on open banking in the U.K.

 

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)

  • 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 – Caroline D. Pham (Acting Chairman effective January 20, 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

Practice Areas

Bank Regulatory

Financial Services


For More Information

Image: Kris Knabe
Kris Knabe

Of Counsel, Litigation Department