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PH FedACTion: Financial Regulatory Updates

Daily Financial Regulation Update -- Monday, December 15, 2025

December 15, 2025

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

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Major Developments

Office of the Comptroller of the Currency

OCC Announces Conditional Approvals for Five National Trust Bank Charter Applications

December 12, 2025

The Office of the Comptroller of the Currency announced its conditional approval of five national trust bank charter applications: First National Digital Currency Bank, NA, Ripple National Trust Bank, BitGo Bank & Trust, NA, Fidelity Digital Assets, NA and Paxos Trust Company, NA.

 

Federal Agencies

Federal Reserve Board

Federal Reserve Board Publishes Working Papers

December 12, 2025

The Federal Reserve Board published the following working papers:

 

Federal Reserve Bank of New York

Report: ‘Less for You, More for Me: Credit Reallocation and Rationing Under Usury Limits’

December 12, 2025

The Federal Reserve Bank of New York published a staff report titled “Less for You, More for Me: Credit Reallocation and Rationing Under Usury Limits.”

 

Blog: ‘The New York Fed DSGE Model Forecast — December 2025’

December 12, 2025

The Federal Reserve Bank of New York published a Liberty Street Economics blog post titled, “The New York Fed DSGE Model Forecast — December 2025.”

 

Securities and Exchange Commission

SEC Issues Investor Bulletin on Crypto Asset Custody Basics for Retail Investors

December 12, 2025

The Securities and Exchange Commission’s Office of Investor Education and Assistance issued an Investor Bulletin to help educate retail investors about how they can hold crypto assets.

 

Commodity Futures Trading Commission

CFTC Announces Implementation of US Treasury Market Reforms

December 12, 2025

The Commodity Futures Trading Commission approved a proposed order to grant a limited exemption necessary for the Chicago Mercantile Exchange and the Fixed Income Clearing Corporation to make their existing cross-margining arrangement available to certain customers with appropriate safeguards.

 

International

European Banking Authority

EBA Publishes Final Draft Technical Standards on Structural Foreign Exchange

December 12, 2025

The European Banking Authority issued final Regulatory Technical Standards on structural foreign exchange under the Capital Requirements Regulation.

 

Bank of England

Working Paper: ‘Sticky hurdles: the dynamics of firm hurdle rates in a tightening cycle’

December 12, 2025

The Bank of England published a staff working paper titled “Sticky hurdles: the dynamics of firm hurdle rates in a tightening cycle.”

 

Bank of England/Ipsos Inflation Attitudes Survey — November 2025

December 12, 2025

The Bank of England released the Inflation Attitudes Survey for November 2025.

 

Financial Conduct Authority

FCA Confirms Final Guidance to Tackle Serious Non-Financial Misconduct in Financial Services

December 12, 2025

The Financial Conduct Authority (FCA) released guidance to support firms to tackle bullying, harassment and violence in financial services in response to firms’ request for additional support.

 

FCA Releases Findings on Wholesale Banks’ Best Execution in UK-Listed Cash Equities

December 12, 2025

The FCA released findings from its multi-firm review of how wholesale banks deliver best execution in U.K.-listed cash equities.

 

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

Global Finance


For More Information

Image: Kris Knabe
Kris Knabe

Of Counsel, Litigation Department