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PH FedACTion: Financial Regulatory Updates

Daily Financial Regulation Update -- Thursday, October 2, 2025

October 02, 2025

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

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Federal Agencies

Federal Deposit Insurance Corporation
Federal Reserve Board
National Credit Union Administration
Office of the Comptroller of the Currency
Farm Credit Administration

Agencies Remind Institutions to Continue Lending When National Flood Insurance Program Is Unavailable

October 1, 2025

The Federal Deposit Insurance Corporation, Federal Reserve Board, National Credit Union Administration, Office of the Comptroller of the Currency and Farm Credit Administration issued a reminder to lenders that they may continue to make loans that are subject to the federal flood insurance statutes when the National Flood Insurance Program is not available.

 

Federal Reserve Board

OIG Issues Update on Ongoing Work

October 1, 2025

The Office of Inspector General of the Federal Reserve Board issued an update on ongoing work.

 

Federal Reserve Bank of New York

Blog: ‘A Historical Perspective on Stablecoins’

October 1, 2025

The Federal Reserve Bank of New York published a Liberty Street Economics blog post titled “A Historical Perspective on Stablecoins.”

 

Securities and Exchange Commission

SEC Issues No-Action Letter Relating to Custody of Crypto Assets With State Trust Companies

September 30, 2025

The Securities and Exchange Commission’s Division of Investment Management issued a no-action letter stating that it would not recommend enforcement action to the commission against registered advisers or regulated funds for maintaining crypto assets and related cash and cash equivalents with certain state-chartered financial institutions.

 

Commodity Futures Trading Commission

CFTC Staff Issues Advisory on Certain Contract Markets

September 30, 2025

The Commodity Futures Trading Commission (CFTC) staff issued an advisory to futures commission merchants, introducing brokers, designated contract markets, derivatives clearing organizations and registered futures associations to certain contract markets regarding preparations with respect to potential market disruption during a lapse in government appropriations.

 

CFTC Issues Federal Register Notice Regarding Operations During Lapse in Appropriations

September 30, 2025

The CFTC issued a notice to provide for the continuation, shutdown and resumption of certain operations in the event of a lapse in appropriations and to alert all persons regulated by or engaged in proceedings at the commission of these provisions.

 

National Credit Union Administration

NCUA to Remain Open, Credit Union Members’ Shares Insured, During Shutdown

October 1, 2025

The National Credit Union Administration (NCUA) will remain open and individual accounts will remain federally insured during the federal government shutdown.

 

NCUA Chairman Issues Statement on ‘Regulation by Enforcement’

October 1, 2025

The NCUA Chairman Kyle S. Hauptman issued a statement about NCUA’s “No Regulation-by-Enforcement Policy.”

 

Ginnie Mae

Ginnie Mae: Lapse in Appropriation Will Not Impact Core Functions

October 1, 2025

Ginnie Mae announced it will continue to perform all functions necessary to ensure that there is no disruption in the market during a potential lapse in appropriations.

 

International

European Banking Authority

EBA Publishes 2026 Work Program

October 1, 2025

The European Banking Authority published its Work Program outlining the key priorities and initiatives for 2026 and announced that it is taking action for a more efficient regulatory and supervisory framework in the EU.

 

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 Michelle W. Bowman (sworn in November 26, 2018)
  • Governor Christopher J. Waller (sworn in December 18, 2020)
  • Governor Lisa D. Cook (sworn in September 13, 2022; purportedly terminated August 25, 2025)
  • 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)

  • Vice Chairman Vacant
  • Director Vacant
  • Director Rodney Hood (Acting 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 – Brian Quintenz (nominated February 11, 2025); Caroline D. Pham (Acting Chairman effective January 20, 2025)

Consumer Financial Protection Bureau – Jonathan McKernan (nominated February 11, 2025); 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: Lawrence D. Kaplan
Lawrence D. Kaplan

Of Counsel, Corporate Department

Image: Jason Shafer
Jason Shafer

Of Counsel, Corporate Department

Image: Kris Knabe
Kris Knabe

Of Counsel, Litigation Department