In January 2021, Congress enacted the William M. (Mac) Thornberry National Defense Authorization Act, of which the Anti-Money Laundering Act (AML Act) was a component. With the passage of the AML Act, Congress stated that it was seeking to modernize and strengthen the AML/CFT regulatory framework, which had not seen comprehensive reform or modernization since the Bank Secrecy Act (BSA) was enacted in 1970.
The Federal Deposit Insurance Corporation (FDIC) and Office of the Comptroller of the Currency (OCC) published a proposed rule in the Federal Register this month to amend regulations that prescribe anti-money laundering and countering the financing of terrorism (AML/CFT) program requirements for banks in a way that aligns with the rule concurrently proposed by the Financial Crimes Enforcement Network (FinCEN) under BSA.
The agencies have proposed to amend their rules concurrently with FinCEN so that program requirements for banks remain consistent with those imposed by FinCEN. Further, with consistent regulatory text, banks will not be subject to additional burden or confusion from needing to comply with differing standards between FinCEN and the agencies. Through proposed rules, FinCEN and the agencies seek to make the changes intended by Congress. The following in an overview of key components from the proposed rules.
FinCEN Proposed Rule
The AML Act mandates that FinCEN establish public government-wide AML/CFT priorities and issue regulations incorporating the priorities into revised program requirements. FinCEN’s proposal requires financial institutions to review the AML/CFT Priorities (as that term is defined within the proposal) and, as appropriate, incorporate them into their risk assessment processes. Notably, financial institutions will not be required to incorporate the priorities into their risk-based AML/CFT programs until the final rule comes into effect.
Establishing and Maintaining an AML/CFT Program
The proposed rule also refocuses supervisory expectations on effectiveness by distinguishing between deficiencies stemming from the program’s design (“establishment”) on the one hand, or failures in the program’s operation (“maintenance”) on the other.
Under the proposed rule, establishing a program would require a financial institution to design a risk-based AML/CFT framework incorporating four core required pillars:
1. Internal policies, procedures, and controls including risk assessment processes and, when applicable, ongoing customer due diligence;
2. Independent program testing;
3. Designation of a U.S.-based compliance officer; and
4. Ongoing employee training.
Establishing an AML/CFT program would also require keeping the program current as a financial institution’s risk profile evolves. Maintaining an AML/CFT program would require an institution to implement its program in all material respects, meaning to execute the program in practice.
Special Focus
Internal Policies, Procedures, and Controls
As noted, BSA requires financial institutions to develop “internal policies, procedures, and controls” as part of their AML/CFT programs. The proposed rule would require that a financial institution’s internal policies, procedures, and controls be reasonably designed to identify, assess, and document money laundering, the financing of terrorism, and other illicit finance risks (ML/TF risks) through risk assessment processes. A financial institution would be required to mitigate ML/TF risks consistent with its risk assessment processes, including by allocating more attention and resources toward higher-risk customers and activities rather than toward lower-risk customers and activities. The proposed rule would place existing requirements for certain financial institutions to conduct ongoing Customer Due Diligence (CDD) under the internal policies, procedures, and controls pillar. FinCEN believes that including the ongoing CDD obligation under this pillar more accurately reflects how financial institutions operationalize ongoing CDD as part of their overall AML/CFT programs.
Risk Assessment Processes
Although financial institutions commonly maintain risk assessment processes, current AML/CFT program rules do not require them in a uniform manner across institution types. The proposed rule would use consistent language to require risk assessment processes as part of a financial institution’s internal policies, procedures, and controls. Risk assessment processes would have to: (1) evaluate the ML/TF risks of the financial institution’s business activities, including products, services, distribution channels, customers, and geographic locations; (2) review and, as appropriate, incorporate the AML/CFT Priorities; and (3) be updated promptly upon any change that the financial institution knows or has reason to know significantly changes the institution’s ML/TF risks.
Independent Testing
The proposed rule would retain the BSA requirement that financial institutions have an independent audit function to test their AML/CFT programs. The proposal clarifies the expectation that independent testing should be based on objective criteria designed to assess whether a financial institution has effectively established, implemented, and resourced an AML/CFT program consistent with its risk assessment processes; auditors should not substitute their own subjective judgment in place of the financial institution when carrying out this requirement. Independent testing must assess compliance, focus on program effectiveness, be conducted by individuals or parties who are truly independent of the AML/CFT function, and avoid conflicts of interest. Financial institutions would retain flexibility in how this requirement is met.
AML/CFT Program Compliance Officer Located in the United States
The proposed rule includes the BSA requirement that financial institutions must have a designated compliance officer. The existing AML/CFT program rules contain variations in the description of this requirement, so the proposed rule would provide clarifying language. The proposed rule would require that financial institutions designate a person responsible for establishing, implementing, and overseeing day-to-day compliance with BSA requirements (the AML/CFT Officer). Consistent with the AML Act, the proposed rule would require that the AML/CFT Officer be located in the United States and accessible to FinCEN and the appropriate Federal regulators. However, while the AML/CFT Officer must be located in the United States, personnel located outside of the United States would still be permitted to perform certain AML/CFT functions. The proposed rule would not alter existing regulations and guidance that generally prohibit the sharing of suspicious activity reports (SARs) with personnel located outside of the United States other than in limited circumstances, such as sharing with a bank’s foreign head office or controlling company.
April 2026
Volume 31, Number 10
Wisconsin Bankers Association
4721 South Biltmore Lane, P.O. Box 8880, Madison, Wisconsin, 53708-8880
Wisconsin Bankers Association. All rights reserved. Reproduction by any means of the entire contents or any portion of this publication without prior written permission is strictly prohibited. This publication is intended to provide accurate information in regard to the subject matter covered as of the date of publication; however, the information does not constitute legal advice. If legal advice or other expert assistance is required, the services of a competent and professional person should be sought.
Special Focus
Ongoing Employee Training Program
The proposed rule would standardize the AML/CFT training requirement across all program rules by uniformly adopting the BSA’s statutory language requiring an “ongoing employee training program,” a clarifying rather than substantive change. FinCEN would generally expect training to reflect the institution’s internal controls, risk assessment results, and current regulatory requirements, with frequency and content tailored to the institution’s risk profile and personnel roles. The risk-based approach allows institutions flexibility in determining which employees and non-employees require ongoing training.
Access to and Approval of a Written AML/CFT Program
The proposed rule would standardize the generally applicable requirement in AML/CFT program rules that financial institutions maintain a written AML/CFT program and make it available upon request to FinCEN, appropriate Federal regulators, or their designees. The proposed rule would also require the program to be approved by the board of directors, an equivalent governing body, or appropriate senior management, clarifying and harmonizing existing approval requirements while allowing flexibility based on an institution’s structure. The proposed changes are intended to promote consistency and strengthen oversight without creating new substantive documentation obligations.
Supervision and Enforcement of Banks’ AML/CFT Programs
The proposed rule outlines a potential FinCEN enforcement and supervisory policy for banks’ AML/CFT programs. Specifically, if a bank has established its AML/CFT program under the proposed rule, FinCEN generally would not take an enforcement action. FinCEN, or other agencies acting on its behalf, generally would not take a significant supervisory action against the bank, unless the bank has a significant or systemic failure to maintain that program. The proposed rule enhances FinCEN’s role in AML/CFT supervision by introducing a notice and consultation framework requiring Federal banking supervisors, before initiating a significant AML/CFT supervisory action under delegated authority, to give FinCEN’s Director at least 30 days’ advance written notice, absent urgent circumstances, to review and provide input on the potential action. In determining whether to pursue an enforcement action or a significant supervisory action, or when reviewing a proposed supervisory action by a Federal banking supervisor, FinCEN’s Director would consider (1) the four statutory factors noted above that are required by the AML Act, (2) the extent to which the bank advances AML/CFT priorities by providing highly useful information to law enforcement or national security officials, and (3) whether the bank is employing innovative tools such as artificial intelligence that demonstrate the effectiveness of the bank’s AML/CFT program, among other considerations that FinCEN’s Director may deem appropriate.
Other Changes to AML/CFT Programs
The proposed rule would make technical and clarifying revisions to FinCEN’s AML/CFT program regulations to improve consistency across financial institution types. The changes include renumbering provisions, updating cross-references and statutory citations to reflect the AML Act and Corporate Transparency Act, revising definitions (such as “Bank Secrecy Act” and “Federal functional regulator”), adding a definition of “AML/CFT Priorities,” and replacing references to AML programs with “AML/CFT programs” where appropriate.
The proposed rule would consolidate separate bank program rules into a single standard applicable to all banks, harmonize and modernize requirements for casinos and money services businesses (MSBs) while retaining certain MSB-specific provisions, and remove outdated compliance dates and unnecessary cross-references to other regulations. The rule would also provide greater flexibility regarding AML/CFT program approval for most financial institutions, streamline provisions requiring compliance with other applicable rules, and maintain certain self-regulatory organization requirements for broker-dealers and futures commission merchants. Overall, the changes are intended to enhance clarity, consistency, and efficiency without altering substantive compliance obligations.
The Role of the Federal Banking Supervisors
FinCEN’s proposed rule was prepared in consultation with the Federal banking agencies, comprised of the Board of Governors of the Federal Reserve System (FRB), FDIC, OCC, and National Credit Union Administration (NCUA). The Federal banking supervisors will also issue their own proposed AML/CFT program rules, in substantive alignment with FinCEN’s proposed rule. At the time of this article, FRB had not yet published its proposal.
Proposed Effective Date and Comment Period
The agencies proposed an effective date of twelve months from the date of issuance of the final rule to allow sufficient
Special Focus Special Focus
time for banks to review and implement the requirements of the proposed rule. The agencies solicit comment regarding the proposed effective date. In addition, the agencies seek comment on all aspects of the proposed amendments but specifically seek comment on the questions listed in the proposed rules. Comments on both proposals are due June 9, 2026
WBA will be filing comments regarding the proposed rules. If you have any questions regarding the proposals or wish to share your comments with WBA, please contact WBA Legal at wbalegal@wisbank.com
FinCEN’s proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-10/pdf/2026-07033.pdf
The FDIC/OCC proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-10/pdf/2026-06948. pdf
FDIC Rescinds Supervisory Guidance on Multiple Re-Presentment NSF Fees
On April 10, 2026, the Federal Deposit Insurance Corporation (FDIC) rescinded its supervisory guidance addressing multiple non-sufficient funds (NSF) fees arising from the re-presentment of the same transaction. The rescission removes the agency’s 2022 and 2023 Financial Institution Letters (FILs) that had significantly shaped examination scrutiny and enforcement in this area. It was effective immediately upon publication.
Background on FDIC Guidance
In August 2022, FDIC issued FIL-40-2022, Supervisory Guidance on Multiple Re-Presentment NSF Fees (for more information see the August 2022 WBA Compliance Journal). The guidance related to situations where a check or ACH item was returned for insufficient funds and later re-presented by a merchant, resulting in multiple NSF fees associated with the same underlying transaction.
FDIC stated that charging multiple NSF fees in these circumstances could present heightened risks of violations of Section 5 of the Federal Trade Commission (FTC) Act, particularly where disclosures did not clearly inform depositors that re-presentment could result in additional NSF fees. The guidance also described circumstances under which the practice could be considered unfair, even when outlined in disclosures, such as when multiple fees were assessed in a short period of time without a meaningful opportunity for consumers to avoid them.
In June 2023, FDIC rescinded and replaced that original 2022 guidance with FIL-32-2023, Clarifying Supervisory Approach Regarding Supervisory Guidance on Multiple Re-Presentment NSF Fees. The revised FIL reaffirmed FDIC’s position that multiple re-presentment NSF fees could raise both deceptive and unfairness concerns and continued to set forth expectations regarding self-identification, corrective action, restitution lookbacks, and examiner treatment during compliance examinations.
Supervisory and Industry Response
Following issuance of the above FILs, FDIC examiners began closely scrutinizing deposit account disclosures and overdraft practices to determine whether they adequately addressed re-presentment concerns. Banks were criticized or cited when disclosures did not clearly state that multiple NSF fees could be charged on the same transaction. In some cases, banks were required to conduct lookback reviews and provide customer restitution.
WBA and other trades expressed grave concern over the approach taken through supervisory guidance. The topic was featured during WBA’s annual Washington, D.C. trip, as well as industry trade letters. Advocacy efforts pointed out how the guidance imposed new substantive requirements without statutory authority or notice-and-comment rulemaking under the Administrative Procedure Act.
In 2023, a Minnesota-based bank and the Minnesota Bankers Association (MBA) filed suit challenging the guidance as arbitrary, capricious, and beyond FDIC’s authority. At the appellant level, WBA signed on to a joint amicus brief filing in support of MBA challenging a District Court decision by pointing out the impacts of the FIL, how the letter very much
acted as a final rule, that the FILs should be deemed reviewable final agency action, and that the District Court decision should be reversed. Unfortunately, the industry lost on appeal. However, in court proceedings to make the argument to the courts that FILs are not binding rules, FDIC had to ensure there were no consequences attached to the FILs. FDIC ensured there were no consequences by no longer examining banks for the issue and citing banks for UDAP violation described in the FILs.
FDIC’s Rescission
As stated above, FDIC rescinded FIL-32-2023. FDIC explained its rationale as being that after review and assessment, the guidance was overly broad in scope and raised uncertainty regarding when disclosures about re-presentments might result in unfairness concerns under the FTC Act.
The rescission does not replace the prior guidance with a new supervisory framework. Instead, FDIC removed the FIL entirely.
While the previous guidance has been fully rescinded, banks should remain mindful to still comply with existing laws and regulations. FDIC specifically noted that supervised institutions should continue to ensure that disclosures accurately reflect actual practices and are provided in accordance with applicable legal requirements.
Practical Considerations
While the rescission means compliance on this matter will no longer be driven by previous guidance documents, it does not eliminate all risk associated with multiple re-presentment NSF fees or need to be mindful of overdraft disclosures and practices.
Unfair and deceptive standards under the FTC Act remain applicable. Examiners may still evaluate whether disclosures are clear and accurate and whether practices cause substantial consumer injury that is not reasonably avoidable. The rescission means that such evaluations will no longer be tied to the specific interpretations outlined in FIL-32-2023.
Additionally, litigation risk persists. Some banks may have encountered demand letters from customers or their attorneys. Plaintiffs may continue to assert breach of contract and consumer protection claims based on account agreements and marketing materials.
Banks may have previously decided to revise disclosures or fee practices in response to the FILs. Despite rescission of the FILs there remains reason for the disclosure or fee practice changes to remain going forward. Each bank should consider what is appropriate based upon operational practice, existing regulatory requirements, expectations, and risk. What is clear, however, is that disclosures should remain clear and understandable by customers.
Lastly, a note on the other supervisory agencies. While FDIC’s guidance was the focus of the 2022-2023 re-presentment matters, both the Office of the Comptroller of the Currency (OCC) and Board of Governors of the Federal Reserve (FRB) issued their own interpretations. OCC discussed re-presentment fees in Bulletin 2023-12, Overdraft Protection Programs: Risk Management Practices. The bulletin covered the issue from a broader risk management context rather than establishing a presumption of unfairness or imposing prescriptive disclosure or restitution expectations. Similarly, FRB addressed re-presentment NSF fees in its Consumer Compliance Outlook: Second Issue 2023. These supervisory observations described instances where charging NSF fees on re-presented transactions was cited as an unfair practice under Section 5 of the FTC Act based on institution-specific findings.
As of writing this article, neither OCC nor FRB have rescinded or otherwise issued further guidance regarding re-presentment.
Special Focus
Conclusion
FDIC’s rescission of its FILs on multiple re-presentment NSF fees marks a significant shift from its previous stance. While the action removes a source of past examination pressure, banks must maintain accurate disclosures and fair NSF fee practices.
The rescission of FDIC’s supervisory guidance on multiple re-presentment NSF fees may be viewed at: https://www.fdic. gov/news/financial-institution-letters/2026/fdic-rescinds-supervisory-guidance-multiple-re-presentment?source=govdelivery&utm_medium=email&utm_source=govdelivery
effective 06/09/2026. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-10/pdf/202606947.pdf Federal Register, Vol. 91, No. 69, 04/10/2026, 18279-18294.
Agencies Propose Revisions to Regulatory Capital Rules.
The Board of Governors of the Federal Reserve System (FRB), Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC) (collectively, the agencies) issued a proposed rule to modernize the capital requirements applicable to Category I and II depository institution holding companies and depository institutions, as well as to revise the market risk capital framework for banking organizations with significant trading activity. The proposal would enhance risk sensitivity and consistency by simplifying core components. The agencies expect the proposal would support the safety and soundness of covered banking organizations and U.S. financial stability while promoting lending and other financial intermediation activities in the banking system over a range of economic conditions. Comments are due 06/18/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-03-27/pdf/202605959.pdf Federal Register, Vol. 91, No. 59, 03/27/2026, 14952-15329.
The Board of Governors of the Federal Reserve System (FRB), Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC) (collectively, the agencies) issued a proposed rule to modify the regulatory capital rule. In particular, the proposal would revise the risk-based capital treatment of certain exposure categories under the standardized approach, focusing on improving the calibration and risk sensitivity of risk weights that are particularly material to covered banking organizations’ lending activities. The proposed rule would also modify the definition of regulatory capital by removing the threshold-based deduction for mortgage servicing assets for all banking organizations subject to the regulatory capital rule, including banking organizations subject to the community bank leverage ratio framework. In addition, the proposed would require Category III and IV banking organizations to recognize most elements of accumulated other comprehensive income in their regulatory capital. Comments are due 06/18/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-03-27/pdf/2026-05960.pdf. Federal Register Vol. 91, No. 59, 03/27/2026, 15332-15452.
CFPB Seeks Comment on Information Collections.
The Bureau of Consumer Financial Protection (CFPB) seeks comment regarding an information collection titled, Interstate Land Sales Full Disclosure Act (ILSA), Regulations J, K, and L. Information is submitted to CFPB to assure compliance with ILSA and the implementing regulations. CFPB also investigates developers who are not in compliance with the regulations. Comments are due 04/20/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR2026-03-20/pdf/2026-05516.pdf Federal Register, Vol. 91, No. 54, 03/20/2026, 13594-13595.
CFPB seeks comment regarding an information collection titled, Mortgage Acts and Practices, Advertising, Regulation N. Regulation N prohibits misrepresentations about the terms of mortgage credit products in commercial communications and requires that covered persons keep certain related records for a period of twenty-four months from last dissemination. The information that Regulation N requires covered persons to retain is necessary to ensure efficient and effective law enforcement to address deceptive practices that occur in the mortgage advertising area. Comments are due 04/20/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-03-20/pdf/2026-05515.pdf Federal Register, Vol. 91, No. 54, 03/20/2026, 13595.
Agencies Codify Elimination of Reputation Risk from Supervisory Programs.
The Federal Deposit Insurance Corporation (FDIC) and Office of the Comptroller of the Currency (OCC) (collectively, the agencies) issued a final rule to codify the elimination of reputation risk from their supervisory programs. Among other things, the rule prohibits the agencies from criticizing or taking adverse action against an institution on the basis of reputation risk. The final rule also prohibits the agencies from requiring, instructing, or encouraging an institution to close an account, to refrain from providing an account, product, or service, or to modify or terminate any product or service on the basis of a person or entity’s political, social, cultural, or religious views or beliefs, constitutionally protected speech, or solely on the basis of politically disfavored but lawful business activities perceived to present reputation risk. The final rule further forbids the agencies from taking any supervisory action or other adverse action against an institution, a group of institutions, or the institution-affiliated parties of any institution that is designed to punish or discourage an individual or group from engaging in any lawful political, social, cultural, or religious activities, constitutionally protected speech, or, for political reasons, lawful business activities that the agencies or its personnel disagree with or disfavor. The final rule is
CFPB seeks comment regarding an information collection titled, Prohibition on Inclusion of Adverse Information in Consumer Reporting in Cases of Human Trafficking, Regulation V. The consumer disclosures included in Regulation V are designed to alert consumers of information shared with a consumer reporting agency (CRA) and their rights related to prohibiting CRAs from furnishing a consumer report containing certain adverse item(s) of information. Comments are due 04/29/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-03-30/pdf/2026-06100.pdf Federal Register, Vol. 91, No. 60, 03/30/2026, 15604-15605.
FRB Announces Final Approval of Information Collection.
The Board of Governors of the Federal Reserve System (FRB) announced final approval of an information collection titled, Notice of Branch Closure. The reporting, recordkeeping, and disclosure requirements regarding the closing of any branch of an insured depository institution (IDI) are contained in section 42 of the Federal Deposit Insurance Act, as supplemented by an interagency policy statement on branch closings. FRB uses the information collected to fulfill its statutory obligation to supervise state member banks. Each IDI must adopt a policy regarding the closing of its branches. When a branch is scheduled for closing, the IDI must notify both its appropriate regulator and customers of the proposed
closure. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-03-17/pdf/2026-05175.pdf. Federal Register, Vol. 91, No. 51, 03/17/2026, 12801-12802.
FRB Proposes to Permit FedNow Participants to Use Intermediaries to Send Transfers.
nt.
FRB issued a proposed rule to amend subpart C of Regulation J (governing the FedNow® Service) to permit FedNow participants to use intermediaries, other than Reserve Banks, to send funds transfers through the FedNow Service. FRB believes the change could support private-sector cross-border payment solutions by allowing FedNow participants to leverage an intermediary (e.g., a correspondent bank) for the international portion of a cross-border transaction and use the FedNow Service for the U.S. domestic portion. Comments are due 06/09/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-10/pdf/2026-06996.pdf Federal Register, Vol. 91, No. 69, 04/10/2026, 18330-18333.
FRB Seeks Comment on SAFE Act Information Collection.
FRB seeks comment regarding an information collection titled, Registration of Mortgage Loan Originators. The information collection is used to evidence compliance with requirements under the Secure and Fair Enforcement for Mortgage Licensing Act (SAFE Act) and Regulation G, which implements the SAFE Act. Comments are due 05/18/2026 The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-03-17/pdf/2026-05172.pdf Federal Register, Vol. 91, No. 51, 03/17/2026, 12800-12801.
FDIC Clarifies Deposit Insurance Coverage for Branches of U.S. Banks.
The Federal Deposit Insurance Corporation (FDIC) issued a final rule to provide that FDIC will insure deposits of all branches of U.S.-insured depository institutions in the Federated States of Micronesia, the Republic of the Marshall Islands, and the Republic of Palau, whether operating presently or in the future. The final rule is effective 04/22/2026 The final rule may be viewed: https://www.govinfo.gov/content/pkg/FR-2026-03-23/pdf/2026-05652.pdf Federal Register, Vol. 91, No. 55, 03/23/2026, 13703-13705.
FDIC Rescinds Policy Statement on Qualifications for Failed Bank Acquisitions.
FDIC announced the rescission of its Statement of Policy on Qualifications for Failed Bank Acquisitions issued in September 2009 and related questions and answers posted on its website in January and April 2010. The policy statement included onerous and highly prescriptive measures, including capital standards that would not be applicable in any other failed bank acquisitions; imposition of an agreement to a cross guarantee with respect to substantially commonly-owned depository institutions; limits on transactions with affiliates that are more restrictive than Sections 23A and 23B of the Federal Reserve Act; and lengthy continuity of ownership requirements. FDIC is concerned that aspects of the policy statement may discourage and potentially limit investments by nonbanks in connection with the resolution of failed depository institutions. Accordingly, FDIC rescinded the policy statement. The rescission is effective 03/23/2026 The recission may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-03-23/pdf/2026-05646.pdf Federal Register, Vol. 91, No. 55, 03/23/2026, 13847-13848.
FDIC Announces Intent to Terminate Receivership.
Notice is hereby given that FDIC, as Receiver, for the institution listed in the notice, intends to terminate its receivership for the institution. The liquidation of the assets for the receivership has been completed. To the extent permitted by available funds and in accordance with law, the Receiver will be making a final dividend payment to proven creditors. Based upon the foregoing, the Receiver has determined that the continued existence of the receivership will serve no useful purpose. Consequently, notice is given that the receivership shall be terminated, to be effective no sooner than thirty days after the date of the notice. If any person wishes to comment concerning the termination of the receivership, such comment must be made in writing, identify the receivership to which the comment pertains, and sent within thirty days of the date of the notice to the address provided within the notice. The notice may be viewed at: https://www. govinfo.gov/content/pkg/FR-2026-04-03/pdf/2026-06525.pdf Federal Register, Vol. 91, No. 64, 04/03/2026, 16944.
FDIC Seeks Comment on GENIUS Act Requirements and Standards.
FDIC seeks comment on a proposal that would implement certain requirements pursuant to the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) applicable to FDIC-supervised permitted payment stablecoin issuers and insured depository institutions, clarify deposit insurance coverage for deposits held as reserve assets for
payment stablecoins, and clarify the treatment of tokenized deposits. Comments are due 06/09/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-10/pdf/2026-06974.pdf. Federal Register, Vol. 91, No. 69, 04/10/2026, 18534-18579.
FDIC Seeks Comments on CRA Information Collection.
FDIC seeks comment regarding an information collection titled, CRA Sunshine. The collection implements a statutory requirement imposing reporting, disclosure, and recordkeeping requirements on community reinvestment-related agreements between insured depository institutions or affiliates, and nongovernmental entities or persons. The information assists in assessing whether the parties are fulfilling their agreements and helps FDIC understand how institutions are fulfilling Community Reinvestment Act (CRA) responsibilities. Comments are due 04/27/2026 The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-03-26/pdf/2026-05836.pdf Federal Register, Vol. 91, No. 58, 03/26/2026, 14699-14700.
OCC Rescinds Guidelines Establishing Standards for Recovery Planning by Certain Financial Institutions.
The Office of the Comptroller of the Currency (OCC) issued a final rule to amend its regulations by rescinding, OCC Guidelines Establishing Standards for Recovery Planning by Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches. OCC believes the recission achieves the goal of identifying and eliminating unnecessary regulatory burden without compromising the safety and soundness of the covered banks or the banking system. Covered banks will no longer be required to develop and maintain formal recovery planning documentation and OCC will no longer examine for recovery planning documentation. Recission of the guidelines does not restrict banks from continuing to engage in recovery planning activities but rather provides bank management the ability to allocate resources more efficiently and pursue the risk management activities best suited to a bank’s business model, management structure, complexities, and risks. Banks remain responsible for managing the risks to their business models. The final rule is effective 05/01/2026. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR2026-04-01/pdf/2026-06281.pdf. Federal Register, Vol. 91, No. 62, 04/01/2026, 16156-16160.
OCC Seeks Comment on Information Collections.
OCC seeks comment regarding an information collection titled, Margin and Capital Requirements for Covered Swap Entities. The Dodd-Frank Act established a comprehensive regulatory framework for derivatives, which are generally characterized as swaps and security-based swaps. The information collection is used in connection with the records requirements of the regulations to ensure compliance. Comments are due 05/12/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-03-13/pdf/2026-04936.pdf. Federal Register, Vol. 91, No. 49, 03/13/2026, 12484-12486.
OCC seeks comment regarding an information collection titled, Privacy of Consumer Financial Information. The information collection is required under the Gramm-Leach-Bliley Act and Regulation P as further explained in the notice. Comments are due 05/06/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-06/ pdf/2026-06558.pdf. Federal Register, Vol. 91, No. 65, 04/06/2026, 17331-17332.
HUD Withdraws Fair Housing and Equal Opportunity Guidance Documents.
The Department of Housing and Urban Development (HUD) announced that the Office of Fair Housing and Equal Opportunity (FHEO) has withdrawn guidance documents as identified in the notice. The documents have been removed from active use and should not be relied upon as authoritative. New internal and external guidance will be issued where necessary and appropriate. The guidance documents have been removed from the HUD.gov website and should not be relied upon by internal or external parties. FHEO is continuing to review its need for existing guidance. Guidance that is determined to be necessary will be reissued. The effective date of the withdrawal is 09/17/2025. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-06/pdf/2026-06624.pdf Federal Register, Vol. 91, No. 65, 04/06/2026, 17291-17292.
Agencies Issue Proposed Rules to Implement GENUIS Act Provisions.
The Department of the Treasury (Treasury) issued a proposed rule to implement section 4(c) of the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act by establishing broad-based principles for
determining when a State-level regulatory regime is substantially similar to the Federal regulatory framework. Comments are due 06/02/2026 The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-03/ pdf/2026-06489.pdf Federal Register, Vol. 91, No. 64, 04/03/2026, 16844-16867.
The Financial Crimes Enforcement Network (FinCEN), together with the Office of Foreign Assets Control (OFAC), issued a proposed rule to implement provisions of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). Specifically, the proposed rule implements the GENIUS Act’s directive to treat permitted payment stablecoin issuers (PPSIs) as financial institutions for purposes of the Bank Secrecy Act, proposes anti-money laundering obligations for PPSIs, and proposes certain specific obligations required by the GENIUS Act for PPSIs. The proposed rule also implements the GENIUS Act’s directive to require PPSIs to maintain effective sanctions compliance programs. Comments are due 06/09/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-202604-10/pdf/2026-06963.pdf Federal Register, Vol. 91, No. 69, 04/10/2026, 18582-18667.
FinCEN Seeks Comment on Whistleblower Program.
The Financial Crimes Enforcement Network (FinCEN) issued a proposing rule to establish a whistleblower program that offers incentives and protections to encourage individuals who have information about potential violations of the Bank Secrecy Act (BSA), International Emergency Economic Powers Act, Trading with the Enemy Act, and Foreign Narcotics Kingpin Designation Act to voluntarily report such information (Whistleblower Program). The proposed rule would implement section 6314 of the Anti-Money Laundering Act and the Anti-Money Laundering Whistleblower Improvement Act, which were enacted into law as part of the National Defense Authorization Act for Fiscal Year 2021 and the Consolidated Appropriations Act of 2023, respectively. The Whistleblower Program will contribute to the U.S. government’s efforts to safeguard the financial system from illicit use, promote national security, and combat money laundering, terrorist financing, proliferation financing, and related crimes. Comments are due 06/01/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-01/pdf/2026-06271.pdf Federal Register Vol. 91, No. 62, 04/01/2026, 16328-16386.
IRS Proposes Guidance on Tax-Exempt Refunding Bonds.
The Internal Revenue Service (IRS) issued a proposed rule that would update certain arbitrage rules and definitions applicable to tax-exempt and other tax advantaged bonds by clarifying the time and manner for requesting refunds of overpayment of rebate to the United States, the special transition rule for transferred proceeds, the limitation on allocations to expenditures, and IRS address for filing defeasance notices. The proposed rule would also revise the provision addressing certain perpetual State guarantee funds, the definition of tax-exempt bond, and the definition of refunding issue. Comments are due 05/11/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/ pkg/FR-2026-03-12/pdf/2026-04798.pdf. Federal Register, Vol. 91, No. 48, 03/12/2026, 12118-12123.
IRS Seeks Comments on Election to Treat Qualified Revocable Trust as Party of Estate.
IRS seeks comment regarding an information collection titled, Election to Treat a Qualified Revocable Trust as Party of an Estate. The form is used to make an election that allows a qualified revocable trust to be treated and taxed (for income tax purposes) as part of its related estate during the election period. Comments are due 05/18/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-03-19/pdf/2026-05393.pdf. Federal Register, Vol. 91, No. 53, 03/19/2026, 13402.
FHFA Orders Stress Testing Reporting by Regulated Entities.
The Federal Housing Finance Agency (FHFA) issued orders, dated 03/05/2025, with respect to stress test reporting as of 12/31/2025, under the Dodd-Frank Act, as amended by the Economic Growth, Regulatory Relief, and Consumer Protection Act. The orders prescribe the scenarios to be used for stress testing and the content and format of required reports. Each order is applicable 03/05/2026. The orders may be viewed at: https://www.govinfo.gov/content/pkg/FR2026-03-12/pdf/2026-04814.pdf Federal Register, Vol. 91, No. 48, 03/12/2026, 12055.
FHFA Reinstates Grandfather Exceptions to Restrictions on Private Transfer Fee Covenants.
FHFA issued a final rule to amend its Private Transfer Fee Covenants (PTFC) Regulation. The regulation restricts Federal National Mortgage Association (Fannie Mae), Federal Home Loan Mortgage Corporation (Freddie Mac) and Federal Home Loan Banks from purchasing, investing in, accepting as collateral, or otherwise dealing in mortgages on properties
Regulatory Spotlight
encumbered by certain types of PTFCs, or related securities, subject to certain exceptions. The technical amendment reinstates timing and transitional applicability (grandfather) exceptions that were removed by FHFA’s 2024 amendments to the PTFC Regulation. The reinstated “grandfather” exceptions are applicable nunc pro tunc beginning 07/16/2012. The final rule is effective 03/17/2026 The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-03-17/ pdf/2026-05160.pdf Federal Register, Vol. 91, No. 51, 03/17/2026, 12673-12675.
SBA
Amends Program Fraud Civil Remedies Act Regulations.
The Small Business Administration (SBA) issued a direct final rule to amend the Program Fraud Civil Remedies Act regulations in 13 CFR part 142 to reflect changes made to the Program Fraud Civil Remedies Act by the Administrative False Claims Act. The changes, among other things, revise the name of the administrative action from “Program Fraud Civil Remedies” to “Administrative False Claims” and increase the threshold for a claim from $150,000 to $1,000,000. The direct final rule is effective 05/04/2026. Comments are due 04/20/2026. If significant adverse comment is received, SBA will publish a timely withdrawal of the direct final rule. The direct final rule may be viewed at: https://www.govinfo. gov/content/pkg/FR-2026-03-19/pdf/2026-05459.pdf. Federal Register Vol. 91, No. 53, 03/19/2026, 13217-13219.
FSA Seeks Comment on Direct Loan Servicing Information Collection.
The Farm Service Agency (FSA) seeks comment regarding an information collection titled, Direct Loan Servicing-Regular. The information is used to determine borrower compliance with loan agreements, assist the borrower in achieving business goals, and regular servicing of the loan account such as graduation, subordination, partial release, use of proceeds, and consent. Comments are due 06/01/2026. The notice may be viewed at: https://www.govinfo.gov/content/ pkg/FR-2026-04-02/pdf/2026-06409.pdf Federal Register, Vol. 91, No. 63, 04/02/2026, 16628-16629.
FCA Announces Business Planning Rule Effective Date.
The Federal Credit Administration (FCA) announced the effective date of the final rule that amended its business planning requirements to comply with Executive Order 14219. The final rule provided the regulation would become effective 30 days after publication in the Federal Register during which either or both houses of Congress are in session. Based on the records of the sessions of Congress, the effective date of the regulation is 03/23/2026. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-03/pdf/2026-06553.pdf Federal Register, Vol. 91, No. 64, 04/03/2026, 16815.
FCIC Removes Regulatory Overreach Provisions.
The Federal Crop Insurance Corporation (FCIC) issued a final rule to amend its regulations regarding determinations and interpretations of the Federal Crop Insurance Act and its associated regulations. The final rule is necessary to align FCIC procedures with Supreme Court precedent and the Administrative Procedure Act, ensuring that interpretive determinations are not improperly characterized as legislative rules. The final rule also removes Federal crop insurance policy provisions from the Code of Federal Regulations (CFR). Policy terms will continue to be published through official program materials and made available on the Risk Management Agency website. The final rule is effective 05/01/2026 The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-01/pdf/2026-06277.pdf. Federal Register, Vol. 91, No. 62, 04/01/2026, 16151-16156.
The Rural Housing Service (RHS) issued a final rule to amend its regulations to grant delegated lenders participating in the Single-Family Housing Guaranteed Loan Program the authority to make loans and obtain loan note guarantees after closing using automated loan underwriting and closing systems. The final rule is effective 06/17/2026. Implementation will occur 09/28/2028. RHS will publish a notice in the Federal Register prior to implementation. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-03-19/pdf/2026-05387.pdf Federal Register, Vol. 91, No. 53, 03/19/2026, 13211-13217.
RHS issued a proposed rule to amend the current Single Family Housing Guaranteed Loan Program regulation. The proposed changes would allow RHS to finance a single-family home with a single or multiple income producing accessory dwelling units. Additionally, the proposed rule would clarify that borrowers can finance properties with features designed to accommodate home-based operations with non-commercial real estate features. Comments are due 06/01/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-03-31/pdf/2026-
06173.pdf Federal Register, Vol. 91, No. 61, 03/31/2026, 15914-15917.
RHS Implements Lender Interactive Test Environment Delegated Authority Pilot Program.
RHS announced implementation of the Lender Interactive Test Environment Delegated Authority Pilot Program for the Section 502 Single Family Housing Guaranteed Loan Program (SFHGLP). The purpose of the pilot program is to test a change in the SFHGLP loan approval process by replacing RHS’ pre-closing loan approval requirement with the delegation of loan approval authority to eligible lenders. The notice provides detailed information about the pilot program. The effective date of the pilot program is 09/01/2026. The pilot program will continue for two years, ending 09/28/2028. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-03-19/pdf/2026-05394.pdf Federal Register, Vol. 91, No. 53, 03/19/2026, 13277-13280.
RHS Announces Single-Family Housing Section 502 Direct Loan Program Pilot.
RHS announced a pilot for the Single-Family Housing Section 502 direct loan program (Section 502) to test alternative values of modest housing for self-help housing and when affordable housing products are provided. RHS intends to evaluate the impact of authorizing the value of properties constructed through the self-help program to exceed the maximum area loan limit under current regulations and permitting grants and other affordable housing products to exceed the area loan limit for all Section 502 loans. See the notice for details about the pilot. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-03-23/pdf/2026-05595.pdf Federal Register, Vol. 91, No. 55, 03/23/2026, 13816-13817.
EBSA Seeks to Clarify Fiduciary Duties in Selecting Designated Investment Alternatives.
The Employee Benefits Security Administration (EBSA) issued a proposed rule that clarifies, and provides a safe harbor for, a fiduciary’s duty of prudence under the Employee Retirement Income Security Act (ERISA) in connection with selecting designated investment alternatives for a participant-directed individual account plan, including asset allocation funds that include alternative assets. The proposal implements President Trump’s Executive Order 14330, Democratizing Access to Alternative Assets for 401(k) Investors. Comments are due 06/01/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-03-31/pdf/2026-06178.pdf. Federal Register, Vol. 91, No. 61, 03/31/2026, 16088-16144.
Agencies Issue Interpretation on Application of Federal Securities Laws to Crypto Assets.
The Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) (collectively, the agencies) issued a final rule to provide an interpretation regarding the application of the Federal securities laws to certain types of crypto assets and certain transactions involving crypto assets. The final rule is effective 03/23/2026 The final may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-03-23/pdf/2026-05635.pdf. Federal Register, Vol. 91, No. 55, 03/23/2026, 13714-13733.
CFTC Withdraws Climate-Related Financial Risk Information Request.
The Commodity Futures Trading Commission (CFTC) announced the withdraw of the information request published in the Federal Register 06/08/2022, on Climate-Related Financial Risk. The withdrawal is effective 03/16/2026 The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-03-18/pdf/2026-05314.pdf. Federal Register, Vol. 91, No. 52, 03/18/2026, 13017-13018.
CFTC Issues Prediction Markets ANPR.
CFTC issued an advance notice of proposed rulemaking (ANPR) regarding event contract derivatives traded on markets commonly referred to as, “prediction markets.” In particular, CFTC seeks information and comment on statutory core principles and CFTC regulations that apply to prediction markets, the types of event contracts that may be prohibited as contrary to the public interest, cost benefit considerations related to prediction markets, and other topics. CFTC may use the information and comments received to inform potential future CFTC action, such as rulemaking. Comments are due 04/30/2026. The ANPR may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-03-16/pdf/2026-05105.pdf Federal Register, Vol. 91, No. 50, 03/16/2026, 12516-12524.
Regulatory Spotlight
SEC Issues Proposed Rule on Publication or Submission of Quotations Without Specified Information.
The Securities and Exchange Commission (SEC) issued a proposed rule to revise a rule that governs certain information gathering and review requirements that brokers and dealers must satisfy before initiating (or resuming) any quotation for a security in a quotation medium other than a national securities exchange. The proposed amendments would revise the rule to refer to only equity securities. Comments are due 05/18/2026 The proposed rule may be viewed at: https://www. govinfo.gov/content/pkg/FR-2026-03-19/pdf/2026-05401.pdf Federal Register, Vol. 91, No. 53, 03/19/2026, 13243-13263.
SEC
Intends to Issue Performance-Based Investment Advisory Fees Order.
SEC announced it intends to issue an order that would adjust for inflation dollar amount thresholds in the rule under the Investment Advisers Act that permits investment advisers to charge performance-based fees to “qualified clients.” Under the rule, an investment adviser may charge performance-based fees if a qualified client has a certain minimum net worth or minimum dollar amount of assets under the management of the adviser. The order would increase, to reflect inflation, the minimum net worth that a qualified client must have under the rule. The order would also increase, to reflect inflation, the minimum dollar amount of assets under management. The notice may be viewed at: https://www.govinfo.gov/content/ pkg/FR-2026-03-31/pdf/2026-06229.pdf Federal Register, Vol. 91, No. 61, 03/31/2026, 15930-15932.
VA Seeks Comment on Information Collections.
The Department of Veterans Affairs (VA) seeks comment regarding an information collection titled, Status of Loan Account, Foreclosure, and Other Liquidation. The information collection is used with a holder’s request for VA to repurchase a loan under 38 CFR 36. The holder of a delinquent vendee account is legally entitled to repurchase of the loan by VA when the loan has been continuously in default for three months and the amount of the delinquency equals or exceeds the sum of two monthly installments. Comments are due 05/11/2026. The notice may be viewed at: https:// www.govinfo.gov/content/pkg/FR-2026-03-12/pdf/2026-04821.pdf. Federal Register, Vol. 91, No. 48, 03/12/2026, 12279-12280.
VA seeks comment regarding an information collection titled, Statement of Purchaser or Owner Assuming Seller’s Loan. The information collection is used to help determine eligibility for release of liability and substitution of entitlement when a VA guaranteed loan is assumed. Comments are due 05/11/2026. The notice may be viewed at: https://www.govinfo. gov/content/pkg/FR-2026-03-12/pdf/2026-04824.pdf. Federal Register Vol. 91, No. 48, 03/12/2026, 12280.
VA seeks comment regarding an information collection titled, Native American Direct Loan (NADL) Processing Requirements. The information collected assists Native American Veterans in obtaining the VA home loan benefit to purchase, construct, or improve dwellings on trust lands, or to refinance existing NADL to a lower interest rate. The information requested by VA is vital to the NADL program’s process and allows VA to determine program eligibility by gathering evidence of Native American Veteran borrowers’ tribal membership status and ownership interest in the land on which the dwelling, or proposed dwelling, is or will be situated. Comments are due 05/26/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-03-24/pdf/2026-05697.pdf. Federal Register, Vol. 91, No. 56, 03/24/2026, 14071.
NCUA Issues Proposed Rule on Third-Party Servicing of Indirect Vehicle Loans.
The National Credit Union Administration (NCUA) seeks comment regarding a proposed rule that would remove the regulation regarding third-party servicing of indirect vehicle loans. The proposal is intended to reduce regulatory burden and provide credit unions with greater operational flexibility, consistent with a principles-based supervisory approach. Comments are due 05/26/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-202603-25/pdf/2026-05797.pdf Federal Register, Vol. 91, No. 57, 03/25/2026, 14484-14486.
Compliance Notes
Banks have reported receiving requests from title companies for information on certain transactions. The requests are related to FinCEN’s residential real estate (RRE) reporting requirements. The RRE rule requires reporting by settlement agents and applies only to non-financed transfers. The reporting requirements do not apply to bank-financed transactions. As a result, banks have no reporting obligations under the RRE rule and are not required to provide information for purposes of RRE reporting. More information regarding the RRE rule may be viewed at: https://www.fincen.gov/rre
FDIC, FRB and OCC issued revised model risk management guidance and have rescinded existing model risk management guidance. The guidance is expected to be most relevant to banking organizations with over $30 billion in total assets. The revised guidance may be viewed at: https://www.fdic.gov/model-risk-management-revised-guidance. pdf
FRB released its latest Consumer Compliance Outlook. It is the first release of 2026. The resource lists topcited FRB compliance violations in 2024 under flood insurance rules, the top FRB-cited Regulation E error resolution violations in 2024, and the 2024 aggregate consumer complaint data for FRB-supervised institutions. The resource may be viewed at: https://www.consumercomplianceoutlook.org/?utm_source=newsletter&utm_medium=email&utm_ content=Consumer%20Compliance%20Outlook&utm_campaign=CCO%20Issue%201%202026/
HMDA LAR data for 2025 are now available on the FFIEC HMDA Platform for approximately 4,768 HMDA filers. The published data contain loan-level information filed by financial institutions and modified to protect consumer privacy. The data may be viewed at: https://ffiec.cfpb.gov/data-publication/modified-lar/2025
FinCEN released its 2025 Year in Review highlighting its efforts in fighting money laundering and terrorist financing. FinCEN reports that $991M has been returned to victims of fraud reported to FinCEN’s Rapid Response Program since 2015. The report also shares information regarding stolen funds returned to victims, advisories and trend analyses shared with the public, and other data that reflects past BSA-related activities by FinCEN. The 2025 report may be viewed at: https://www.fincen.gov/about-fincen/fincen-year-review
FDIC issued the 2026 edition of the Consumer Compliance Supervisory Highlights. The purpose of the publication is to enhance transparency regarding FDIC’s consumer compliance supervisory activities and to provide a high-level overview of consumer compliance issues identified in 2025 through FDIC’s supervision of state non-member banks and thrifts. The edition includes a summary of the overall consumer compliance performance for FDIC-supervised institutions in 2025, a description of the most frequently cited violations, and an overview of consumer complaint trends. The FDIC 2026 Consumer Compliance Supervisory Highlights may be viewed at: https:// www.fdic.gov/bank-examinations/consumer-compliance-supervisory-highlights
FRB, FDIC, and OCC are to host an Ask the Regulators event on May 5, 2026, at 2:00 p.m. ET, to discuss recent proposals that would modernize and revise bank capital requirements. During the session, the agencies will discuss the proposal to revise the standardized approach that sets the risk-based capital requirements for Category III and IV banking organizations and for banking organizations with total consolidated assets of less than $100 billion. In addition, the agencies will briefly discuss a proposal to revise the risk-based capital requirements applicable to Category I and II banking organizations and to banking organizations with significant trading activity.
FRB is also offering free agricultural update and CRE update webinars through its Ask the Fed series in early May. All webinars require registration and may be found at the Ask the Fed website, https://askthefed.org/
Fannie Mae issued Lenders Letter LL-2026-04 which is a governance framework for Fannie Mae Seller/Services’ use of artificial intelligence or machine learning (AI/ML). The guidance is applicable to the extent a seller/servicer uses AI/ML in connection with the origination of loans sold to or guaranteed by Fannie Mae or servicing loans on behalf of Fannie Mae. The Lenders Letter may be viewed at: https://singlefamily.fanniemae.com/news-events/lender-letter-ll-202604-governance-framework-use-artificial-intelligence-and-machine-learning
Fannie and Freddie also issued letters to announce changes to Project Standards & Property Insurance Requirements to help reduce costs related to property insurance. The Fannie and Freddie Lender Letters may be viewed at the following, respectively: https://singlefamily.fanniemae.com/media/44986/display and https://guide.freddiemac.com/app/guide/ bulletin/2026-C
OCC announced the availability of its community bank director and senior management workshops. More information about the workshops may be viewed at: https://occ.gov/publications-and-resources/information-for/bankers/ community-bank-director-workshops/index-community-bank-director-workshops.html
CFPB issued its 2025 Consumer Response Report. The report provides information and analysis about complaints received by CFPB from January 1 through December 31, 2025, including information and analysis about complaint numbers, complaint types, and, where applicable, information about the resolution of complaints. The report may be viewed at: https://files.consumerfinance.gov/f/documents/cfpb_2025-cr-annual-report_2026-03.pdf
FinCEN issued Advisory FIN-2026-A001 urging financial institutions to be vigilant about health care fraud schemes targeting government health care benefit programs such as Medicare and Medicaid. FinCEN’s advisory provides an overview of how fraudsters, organized crime groups, and, increasingly, transnational criminal organizations are targeting government health care benefit programs. It also highlights money laundering typologies and red flag indicators to help identify and report suspicious activity. FinCEN strongly encourages financial institutions to voluntarily report suspicious activity to FinCEN and immediately notify law enforcement of such activity. FinCEN requests that financial institutions reference the Advisory in SAR field 2 (Filing Institution Note to FinCEN) and the narrative by including the key term “HCF-2026-A001” and select, as applicable, SAR field 34(g) (Healthcare/Public or Private Health Insurance) and any other applicable check box. The advisory may be viewed at: https://www.fincen.gov/system/files/2026-03/FinCENAdvisory-Health-Care-Fraud.pdf
May
5-6
BSA/AML Conference
Wisconsin Dells - $495/attendee
6-7 Train the Trainer Boot Camp
Madison – $550/attendee
12 CFO Conference
Madison - $275/attendee
13 Directors Summit
13-14
Madison - $275/attendee
Principles of Banking
Wausau - $550/attendee
19-20 Human Resources Conference
Wisconsin Dells - $350/attendee
19 Trust Conference
Madison - $275/attendee
20-21 Personal Banker School
Madison - $550/attendee
20 Branch Manager Boot Camp: Session I
Four-part series, virtual half days – $900/attendee
TBD Fraud On-Demand Video Series
Five-part video series – $995/bank
June
Dells – $275/attendee
Workshop: Advanced Cash Flow Analysis
full day – $275/attendee
Dells – $300/attendee
Compliance Forum: Session I
Stevens Point – $1,500/bank, 2 primary members 17 Branch Manager Boot Camp: Session II
Four-part series, virtual half days – $900/attendee
2026 Benefit for WBA Advocacy: Kohler Outing
Online Workshop: Wowing the Client! Virtual half-day – $300/attendee
July
15 Branch Manager Boot Camp: Session III
Four-part series, virtual half days – $900/attendee
