September 2026 Compliance Journal

Compliance Journal September 2026

Special Focus Joint Agency Statement on SAR Confidentiality And Available Fraud Resources for Wisconsin Compliance Officers A joint agency statement has been released regarding the confidentiality requirements related to suspicious activity reports (SARs) filed in accordance with the Bank Secrecy Act (BSA). The statement was issued partially in response to comments received in connection with a request of information (ROI) initiative by the Board of Governors of the Federal Reserve System (FRB), Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC) on potential actions the agencies could take to help consumers, businesses, and banks mitigate the risk of payments fraud, with a particular focus on check fraud. Commenters requested the agencies and the Financial Crimes Enforcement Network (FinCEN) to clarify how banks can ensure compliance with SAR confidentiality requirements and provide customers with transparent and timely communication as part of a bank’s fraud investigation, which may result in one or more SAR filings and potential closure of a customer’s account. This article includes information about the joint agency statement and given the inter-connectiveness of the reason for the issuance of the statement and of banks’ efforts to continue the fight against fraud, this article also includes fraud-prevention and reporting resources for compliance officers. Joint Statement of SAR Confidentiality As mentioned above, the agencies issued a statement to clarify confidentiality requirements related to SARs, particularly when banks communicate with customers regarding potentially fraudulent transactions, other suspicious activity, or account closures. The statement was issued September 2, 2026, and does not alter existing BSA legal or regulatory requirements or establish new supervisory expectations. SAR Confidentiality The statement sets forth that SAR confidentiality is a statutory and regulatory requirement that helps to ensure that SAR information is disclosed only for appropriate purposes. In particular, BSA prohibits the disclosure of a SAR or information that would reveal the existence of a SAR, including to a customer or other person who is the subject of the SAR. Unauthorized disclosure of a SAR to that person, and any information that would reveal the existence of a SAR to that person, could undermine ongoing and future law enforcement investigations by alerting potential suspects, deterring financial institutions from reporting suspicious activity and filing SARs, and even endangering SAR filers. However, under FinCEN’s implementing regulation for SAR confidentiality, “a SAR or any information that would reveal the existence of a SAR” does not include “the underlying facts, transactions, and documents upon which a SAR is based.” Accordingly, BSA and its implementing regulations do not prohibit banks from communicating with a customer or other person who is the subject of a SAR or with other third parties, including other banks or credit unions, about potentially fraudulent or other suspicious transactions involving the customer’s account or notifying the customer of the bank’s intention to close the account for potentially fraudulent or other suspicious activity, so long as that communication does not reveal the existence of a SAR.

Special Focus SAR confidentiality does not, for instance, prohibit banks from communicating with a customer or other person who may be the subject of a SAR or with third parties, including other banks or credit unions, when such communication involves the underlying facts, transactions, and documents upon which a SAR is based. Specifically, the factual information related to transactions, including, but not limited to, transaction dates, amounts, and parties, may be discussed assuming there is no communication that would reveal the existence of a SAR to a customer or other person who is the subject of a SAR or to other third parties including other banks or credit unions. The statement includes examples of communications with bank customers that typically are not prohibited by BSA. The statement may be viewed at: https://www.fincen.gov/system/files/2026-09/Joint-Statement-on-SAR-Confidentiality.pdf Fraud Resources Available to Wisconsin Compliance Officers The following is a list of resources for compliance officers to assist in fraud investigation, fraud reporting, and for overall connection to others helping to combat fraud and create awareness of fraud prevention with customers. Relevant links are provided at the end of the article. Wisconsin Resources Wisconsin Department of Financial Institutions (DFI) has many resources on its website, including information about the recent law regarding cryptocurrency kiosks. The information includes a reporting page for complaints of violations. Wisconsin Department of Agriculture, Trade and Consumer Protection (DATCP) operates a Consumer Protection Hotline (800-422-7128) and will provide fact sheets or may send a speaker to a community event on request. DATCP also maintains a “Senior Scams” presentation toolkit that banks can use directly for branch or community presentations rather than building materials in-house. Wisconsin Department of Justice (DOJ) investigates and prosecutes state consumer-law violations and publishes a “Stop Financial Scams” flyer along with elderprotection materials. DOJ also co-runs the Wisconsin Elder Abuse Hotline with the Greater Wisconsin Agency on Aging Resources (GWAAR). The Wisconsin Elder Abuse Hotline is a toll-free line connecting victims, family members, and concerned bankers to local resources and law enforcement referrals. Wisconsin Department of Health Services (DHS) is home for county Adult Protective Services (APS) which is the front-line reporting channel for suspected financial exploitation of an elder or at-risk adult. These agencies are managed on a county level, and DHS maintains a statewide directory. Federal Resources FBI Milwaukee Field Office (IC3) regularly issues fraud-alert tip sheets banks can adapt for customer communications. The IC3 (ic3.gov) is also the standard reporting portal to point customers toward, including its annual Elder Fraud Report. U.S. Secret Service Milwaukee Financial Crimes Task Force is a long-running task force combining Secret Service agents with state and local investigators on financial crimes that frequently target businesses and elderly victims. FinCEN Section 314(b) is a source many bankers are likely already familiar with; however, Page 2 | September 2026

September 2026 Volume 32, Number 4 Wisconsin Bankers Association 4721 South Biltmore Lane, P.O. Box 8880, Madison, Wisconsin, 53708-8880 Senior Writers Heather MacKinnon Scott Birrenkott Editor Ramon Morales Layout Emily Torgerson

Copyright ©2026 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 just this June, FinCEN issued updated guidance explicitly extending the Section 314(b) safe harbor to cover suspected fraud, as part of Treasury’s participation in the federal Task Force to Eliminate Fraud. The goal is to enable participating institutions to utilize it more than as a BSA tool, but directly as a fraud-prevention tool. WBA Resources As mentioned elsewhere in this publication, WBA has launched its “Lock Out Fraud” resource library. This brand new, ever-growing set of consumer-facing fraud materials is designed for member banks to use as they wish. Feel free to use, distribute, and brand with your bank’s logo and distribute through branches, newsletters, and social media. The WBA Fraud Summit and other educational offerings are excellent opportunities to network, receive the latest news, understand recent trends, and stay on top of fraud topics. Many fraud-related educational offerings are made available through the WBA Education department each year. Be sure to visit the Education section of the WBA website for the latest offerings. The Midwest Bankers Insurance Services (MBIS), a WBA-subsidiary, reviews Financial Institution Bond and Cyber Liability applications to help banks assess internal controls and fraud vulnerabilities before a loss occurs. The WBA Financial Crimes Committee is one of WBA’s volunteer banker committees. The group meets throughout the year to plan educational conferences, update resources, work on advocacy and legislative efforts, network, and share ongoing fraud trends, technologies, and overall tips. Committee membership is on an annual basis with new applications accepted in early Spring. Space is limited. Others The ABA Fraud Directory is designed to put banks in touch with the right person at any participating bank. A bank is not required to be an ABA member to use the directory, however, any participating bank must reciprocate directory information so that all may benefit from the information. This is an exceptionally useful tool for when you need to get in touch with a fraud department, or the correct individual to resolve a situation involving another bank you might not already have a working relationship with or otherwise be familiar with. Various fraud email lists also exist for bankers to participate in. These lists often include state agencies and law enforcement. Through collaboration, the banking industry and these partners are able to share information and respond quickly to sudden fraud trends, schemes, and rings. Recommendations for Compliance Officers Perhaps one of the most practical recommendations is to be engaged. Among the resources above, there is not one specific one which will solve every fraud problem. However, by being engaged with many, Wisconsin banks can stay on top of financial crime trends happening across the state (and the nation). Becoming familiar with local law enforcement, the county elder abuse agency, available email lists, and other banks and financial institutions in the area, can go a long way. Additionally, many Wisconsin banks host town-hall-style events within their communities in partnership with local law enforcement or other local officials. The goal is to bring community members together to discuss how to spot and stop fraud. WBA knows that many banks have found success in these events as a way to help distribute information and resources to their local community. Banks should also not hesitate to reach out to law enforcement when the situation warrants it. While banks need to think through privacy matters, also consider whether the situation is one that falls within the privacy regulation exception to protect against or prevent actual fraud, unauthorized transactions, claims, or other liability. Also consider that in circumstances where bank has filed a SAR, it may still be worth reaching out to law enforcement directly to alert them of a situation. The banking agencies allow banks to reach out to law enforcement to discuss a SAR the bank filed. Frontline staff should also be encouraged and reassured to involve management if staff senses that something is off or if additional questions need to be asked and answered before proceeding with a transaction. Fraudsters often plan and hope that bank staff will feel rushed or pressured not to stop to first check with others. September 2026 | Page 3

Special Focus Resources: Joint Agency Statement on SAR Confidentiality: https://www.fincen.gov/system/files/2026-09/Joint-Statement-on-SAR-Confidentiality.pdf Wisconsin DFI Investment Scam Tracker announcement: https://dfi.wi.gov/Pages/About/NewsEvents/ NewsReleases/20240730DFIInvestmentScamTracker.aspx Investor Advisories: https://dfi.wi.gov/Pages/Securities/InvestorResources/InvestorAdvisories.aspx Complaint Reporting Tool: https://apps.dfi.wi.gov/apps/OnlineComplaintSystem/ WI DATCP Consumer Protection: https://datcp.wi.gov/Pages/Programs_Services/ConsumerProtection.aspx Elder Abuse Awareness resources: https://datcp.wi.gov/Pages/WorldElderAbuseAwarenessDay.aspx Wisconsin Elder Abuse Hotline: https://reportelderabusewi.org/ WI DHS Adult Protective Services Directory and Reporting Tool: https://www.dhs.wisconsin.gov/aps/report.htm AARP Effective Ways to Protect Yourself From Scams: https://elearn.aarp.org/Public/Catalog/Home.aspx?Option=463 Milwaukee Police Department Financial Crimes Unit resources: https://city.milwaukee.gov/police/Police-Units-Partners/ Financial-Crimes-Unit/FinancialCrimesResources FBI Milwaukee fraud alert tips: https://www.fbi.gov/contact-us/field-offices/milwaukee/news/fbi-provides-fraud-alerttips-to-identify-potential-scams FinCEN Section 314(b) Fact Sheet: https://www.fincen.gov/sites/default/files/shared/314bfactsheet.pdf MBIS: https://mbisllc.com/ WBA Items Education: https://www.wisbank.com/education/ Article of Fraud Prevention Actions by WBA Members: https://www.wisbank.com/four-wba-member-banks-share-fraudprevention-release-scammers-are-pretending-to-help-but-theyre-really-hacking-into-your-life/ Lock Out Fraud resource library: https://www.wisbank.com/lock-out-fraud/

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Special Focus Agency Statement on Community Banks’ Engagement with Core Service Providers On September 11, 2026, 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 statement to provide clarity on their risk-based supervision of certain services provided to community banking organizations (CBOs). The agencies believe there is a need for additional clarification regarding a subset of CBOs’ third-party relationships, based on the agencies’ supervision of CBOs and their service providers, and reinforced by the agencies’ outreach to CBOs and other relevant stakeholders. The subset consists of third parties that provide the critical systems applications and infrastructure that support the operation and essential functions of one or more of a CBO’s lines of business, including the following examples. For purposes of the statement, the agencies refer to the following activities broadly as core providers: · · · · · · ·

Transaction processing, Account management, Payments processing, Customer relationship management, Compliance and reporting, Online banking, and Other material functions.

These relationships are essential to the safe and sound operations of CBOs, yet certain core provider business practices and market dynamics may pose obstacles to a CBO’s ability to efficiently and effectively identify, assess, and address the attendant risks. As such, the agencies issued the statement to address select aspects of how CBOs engage with core providers, the extent to which the agencies will take these aspects into consideration when determining the level of supervisory oversight of core provider services, and the agencies’ supervisory and enforcement authorities where a core provider engages or causes a CBO to engage in unsafe or unsound practices or violations of law or regulation. Background The agencies stated they are committed to prioritizing reforms targeted at reducing the supervisory and regulatory burden for CBOs and tailoring supervisory and regulatory frameworks to better fit their business models and unique risks. The reforms will better position CBOs to serve their communities and drive economic growth. Most CBOs rely on core providers to support their ability to operate effectively and compete in the rapidly evolving marketplace. The agencies recognize the significant benefits these relationships offer and that core providers represent CBOs’ most material, complex, and highest-risk third-party relationships. While use of core providers can create operational efficiencies, the agencies state it also creates heightened risk, especially if the core provider experiences financial distress, operational failures, or security compromises. The agencies are also aware that a significant percentage of the core provider market is represented by just a few large providers, which limits CBOs’ negotiating power. Given these constraints, CBOs report they often experience challenges obtaining reasonable due diligence information, negotiating contract terms, or conducting effective ongoing monitoring. It can be difficult for CBOs to hold core providers accountable for delivering quality services. Risk-Based Supervision of Core Providers The agencies set forth that each banking organization is responsible for operating in a safe and sound manner and in compliance with applicable laws and regulations and that an important aspect of this responsibility is adopting third-party risk management practices that are commensurate with the organization’s size, complexity, and risk profile and with the nature of its third-party relationships. As part of standard supervisory processes, the agencies examine a banking organization for its management of third-party risk and its operations involving third parties. The agencies also conduct risk-based examinations of certain third parties’ provision of services, including those of certain core providers. September 2026 | Page 5

Special Focus Based on the agencies’ supervisory experience and stakeholders’ input, the agencies have determined that core provider business practices that unreasonably limit CBOs’ ability to conduct due diligence and ongoing monitoring or to negotiate contract terms that address their business needs are associated with greater risks to CBOs and a reduced ability of CBOs to identify, assess, and address such risks. Accordingly, the agencies will consider the following factors when making supervisory allocation decisions relevant to core providers who provide services to CBOs (e.g., decisions regarding the nature, extent, and frequency of supervisory activities applicable to core providers; the contents of examination reports provided to core providers’ client financial institutions; and whether to add a core provider to the agencies’ service provider examination program): ·

Transparency: As part of safe and sound third-party risk management, banking organizations collect information from their third-party service providers through due diligence, contractual mechanisms, and ongoing oversight, tailored to the banking organization’s size, complexity, and risk profile, as well as the nature of its third-party relationships. CBOs that are unable to collect this information are more likely to face challenges effectively and efficiently managing their third-party risks, which, given the criticality of core providers, may be more difficult to mitigate, compared to other less critical third parties. These informational gaps also may present challenges for the agencies’ supervision of these CBOs. As such, the agencies will take into consideration the level of a core provider’s transparency with CBOs in making supervisory allocation decisions regarding core provider examinations. This will be determined through an assessment of a provider’s: 1. 2. 3. 4. 5.

·

Willingness to provide reasonably relevant and timely due diligence information necessary for a CBO to decide whether to enter into a core provider relationship and engage in ongoing monitoring thereafter, Contractual provisions that limit a CBO’s reasonable attempts to compare the core provider’s offerings with those of other providers, Use of, transparency regarding, and compliance with service level agreements using measurable performance standards that reflect a CBO’s individual needs and risk profile, along with provisions that enable a CBO to monitor and enforce the agreements, Transparency and timely disclosure regarding operational issues and security incidents impacting the delivery of services, and Use of complex billing practices that are difficult to reconcile to the services CBOs are receiving.

Contract Features: As part of effective management of third-party risks, a CBO may determine that it either needs to exit a relationship with a core provider that does not meet its needs or has failed to perform adequately or seek supplemental services from alternative providers. However, core provider contract provisions may act as obstacles to a CBO seeking such an exit or supplemental services. As a result, CBOs may be forced to acquiesce to suboptimal core provider relationships wherein CBO needs are less likely to be adequately met and CBOs may have a limited ability to manage third-party risk. In making supervisory resource allocation decisions, the agencies will take into consideration a core provider’s business practices and use of contract terms that make it difficult for CBOs to manage their core provider relationships in a manner that aligns with the CBO’s business needs, such as by seeking an alternative core provider or supplementary services. Such contract terms and practices include, for example, 1. 2. 3. 4.

·

Opaque pricing structures and practices, Opaque billing practices, including extensive “back billing” windows during which the core provider may issue retroactive charges for items missing from prior invoices, Unsupported or contractually undefined core deconversion fees, especially in instances in which the core provider breached contractual terms, provided inadequate services as measured by service level agreements, or violated or may have caused the CBO to violate any laws or regulations, and Excessive limitations on the ability of unaffiliated service providers to integrate with the core platform.

Technology: Core providers that fail to invest in maintaining up-to-date technological solutions may be more likely to experience data breaches or service outages or disruptions, which CBOs have limited ability to oversee or mitigate. As such, the agencies will take into consideration a core provider’s technology investments and capabilities in making supervisory allocation decisions. This includes, for example: September 2026 | Page 6

Special Focus 1. 2. 3.

The number and severity of computer security incidents, Appropriate management of end-of-support and end-of-life assets that enable client CBOs to transition to updated platforms, and Lack of demonstrated operational resilience capabilities.

Supervisory and Enforcement Actions The agencies monitor services that core providers deliver to CBOs to identify issues related to safety and soundness or violations of law. When such issues are identified, the agencies may bring the appropriate actions against core providers and/or the CBO pursuant to their statutory authorities. This does not eliminate or reduce a CBO’s responsibility for ensuring activities are consistent with safe and sound banking practices and in compliance with applicable laws and regulations, regardless of whether they are outsourced to a third party. Among other bases for bringing appropriate actions against core providers, the agencies may have a reasonable basis to determine that certain core providers qualify as “institution-affiliated parties” (IAP) under the Federal Deposit Insurance Act—specifically, as “persons . . . who participate[] in the conduct of the affairs of an insured depository institution.” This determination reflects the operational reality of the CBO-core provider relationship. While CBOs contract with core providers for services, many of the services provided by core providers address unique features of a CBO, are integral to the functioning of the institution and its delivery of banking products and services, and directly impact the customer banking experience. Many CBOs are wholly reliant on core providers for their back-end operations, as well as some of their customer interfaces and other functions. In these arrangements, core providers undertake the most central operational aspects of banking for the CBO, and CBOs often could not provide their services otherwise. Because core providers are integral to carrying out the business of banking and the functions of CBOs, they may be held liable for the practices or violations of a CBO as an institution-affiliated party. Conclusion The interagency statement is meant to provide clarity regarding the agencies’ risk-based supervision of certain services provided by core providers to CBOs. The statement addresses the agencies’ supervisory and enforcement authorities where a core provider engages or causes a CBO to engage in unsafe or unsound practices or violations or law or regulations. When such issues are identified, the agencies may bring the appropriate actions against core providers and/or the CBO pursuant to their statutory authorities. The joint statement may be viewed at: https://occ.gov/news-issuances/news-releases/2026/nr-ia-2026-77b.pdf

Lock Out Fraud: New WBA Resources Help Consumers Stay One Step Ahead Fraudsters are constantly changing their tactics, finding new ways to target consumers through phone calls, text messages, social media, cryptocurrency schemes, and other increasingly sophisticated scams. As these threats continue to evolve, education remains one of the strongest tools available to protect both consumers and the financial institutions they trust. To help address this growing challenge, WBA has launched its new Lock Out Fraud resource page at wisbank.com/ lock-out-fraud/. The initiative provides easy-to-understand, one-page educational resources designed to help consumers recognize common scams, understand warning signs, and take steps to protect themselves from fraud. The growing library currently features resources on topics such as spoofing scams, dealer clone scams, and Bitcoin ATM fraud, schemes that continue to impact consumers across Wisconsin and the country. Each resource is presented in a concise, reader-friendly format that can be quickly shared with customers, family members, employees, and community members. Importantly, WBA member banks may customize these materials by adding their own logo and distributing them directly to customers through branches, newsletters, websites, social media channels, and community outreach efforts. This allows banks to reinforce fraud awareness while providing valuable educational content from a trusted source. Page 7 | September 2026

Special Focus The Lock Out Fraud initiative reflects WBA’s ongoing commitment to supporting the well-being of both member banks and the customers they serve. By providing timely information on emerging fraud trends and prevention strategies, WBA aims to empower consumers with the knowledge they need to remain vigilant and avoid becoming victims. By late fall 2026, the Lock Out Fraud page will feature a comprehensive collection of fraud education materials covering a wide range of scams and consumer protection topics. As fraud threats continue to evolve, one thing remains constant: informed consumers are better protected consumers. Whether you are looking to learn more about a specific scam or seeking resources to share with family and friends, WBA encourages everyone to explore the growing collection of materials available through the Lock Out Fraud initiative. Visit wisbank.com/lock-out-fraud/ today to access the latest resources and learn how to lock out fraud before it reaches your doorstep.

Regulatory Spotlight Interagency Statement on Special Purpose Credit Programs. The Bureau of Consumer Financial Protection (CFPB), Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), Department of Housing and Urban Development (HUD), Federal Housing Finance Agency (FHFA), Department of Justice (DOJ), and National Credit Union Administration (NCUA) (collectively, the agencies) announced rescission of the Interagency Statement on Special Purpose Credit Programs Under the Equal Credit Opportunity Act and Regulation B, dated 02/22/2022. The agencies rescinded the statement to make clear that (1) creditors may not discriminate against borrowers based on prohibited characteristics and (2) creditors should not rely upon the statement or other related issuances going forward. The rescission is effective 08/25/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-25/pdf/2026-17307.pdf. Federal Register, Vol. 91, No. 163, 08/25/2026, 54875-54877.

Agencies Define “Unsafe or Unsound Practices” Under Federal Deposit Insurance Act. The Federal Deposit Insurance Corporation (FDIC) and Office of the Comptroller of the Currency (OCC) (collectively, the agencies) issued a final rule to define the term “unsafe or unsound practice” for purposes of section 8 of the Federal Deposit Insurance Act and to revise the supervisory framework for the issuance of matters requiring attention and other supervisory communications. The final rule is effective 11/02/2026. The final rule may be viewed at: https://www.govinfo. gov/content/pkg/FR-2026-09-01/pdf/2026-17823.pdf. Federal Register, Vol. 91, No. 168, 09/01/2026, 56004-56022. Page 8 | September 2026

Regulatory Spotlight Agencies Issue Regulatory Agendas. The Bureau of Consumer Financial Protection (CFPB) published its agenda as part of the 2026 Unified Agenda of Federal Regulatory and Deregulatory Actions. CFPB reasonably anticipates having the regulatory matters identified in the agenda under consideration during the period from January 2026 to November 2026. The information is current as of 01/13/2026. The regulatory agenda may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-14/pdf/202616613.pdf. Federal Register, Vol. 91, No. 156, 08/14/2026, 53082-53083. The Department of the Treasury (Treasury) issued its regulatory agenda pursuant to the requirements of the Regulatory Flexibility Act and Executive Order 12866, as amended. The regulatory agenda may be viewed at: https://www.govinfo. gov/content/pkg/FR-2026-08-14/pdf/2026-16600.pdf. Federal Register, Vol. 91, No. 156, 08/14/2026, 53050-53052. The Small Business Administration (SBA) issued its regulatory agenda. The agenda is a summary of current and projected rulemakings and completed actions. The regulatory agenda may be viewed at: https://www.govinfo.gov/ content/pkg/FR-2026-08-14/pdf/2026-16611.pdf. Federal Register, Vol. 91, No. 156, 08/14/2026, 53074-53075. The Securities and Exchange Commission (SEC) published the Chairman’s agenda of rulemaking actions pursuant to the Regulatory Flexibility Act. The items listed in the agenda reflect only the priorities of the SEC Chairman, and do not necessarily reflect the views and priorities of any individual Commissioner. Information in the agenda was accurate 05/12/2026, the date on which staff completed compilation of the data. To the extent possible, rulemaking actions by SEC since that date have been reflected in the agenda. Comments are due 09/14/2026. The regulatory agenda may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-14/pdf/2026-16619.pdf. Federal Register, Vol. 91, No. 156, 08/14/2026, 53164-53168. The Federal Trade Commission (FTC) published its regulatory agenda in accordance with the Federal Trade Commission Act, and the Regulatory Flexibility Act, as amended by the Small Business Regulatory Enforcement Fairness Act. The majority of the rulemakings listed in the agenda are being conducted as part of FTC’s systematic review of all of its regulations and guides on a rotating basis. The regulatory agenda may be viewed at: https://www.govinfo.gov/content/ pkg/FR-2026-08-14/pdf/2026-16617.pdf. Federal Register, Vol. 91, No. 156, 08/14/2026, 53156-53157. The Federal Communications Commission (FCC) issued its regulatory agenda pursuant to Executive Order 12866. The agenda entries include a brief description and summary of each regulatory activity that is currently planned for 12 months, subject to revision, including the objectives and legal basis for each, and the name and telephone number of an FCC official who is knowledgeable about items in the agenda. The regulatory agenda may be viewed at: https://www. govinfo.gov/content/pkg/FR-2026-08-14/pdf/2026-16615.pdf. Federal Register, Vol. 91, No. 156, 08/14/2026, 5309253147.

Agencies Propose Revised CRA Rule. The Federal Deposit Insurance Corporation (FDIC) and Office of the Comptroller of the Currency (OCC) (collectively, the agencies) issued a proposed rule to amend their Community Reinvestment Act (CRA) rules by making certain substantive, technical, and process-oriented changes to refocus on the statutory objective of encouraging banks to meet the credit needs of their communities; better ensure that community development grants reach the communities they are intended to benefit; reduce unnecessary burden, particularly for community banks; and provide greater clarity for how to obtain CRA consideration. The agencies also propose certain technical changes to their rules implementing CRA sunshine requirements of the Federal Deposit Insurance Act. In addition, OCC has proposed similar technical changes to its Public Welfare Investments rule and its Rules, Policies, and Procedures for Corporate Activities. Comments are due 10/13/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-12/pdf/2026-16454.pdf. Federal Register, Vol. 91, No. 154, 08/12/2026, 52114-52218.

FDIC Issues Interim Final Rule on Reciprocal Deposits and Implementing the 21st Century ROAD to Housing Act. The Federal Deposit Insurance Corporation (FDIC) issued an interim final rule to amend its brokered deposit regulations to conform with recent changes to section 29 of the Federal Deposit Insurance Act made by section 902 of the 21st Century ROAD to Housing Act related to reciprocal deposits, which took effect 07/11/2026. FDIC also provided certain September 2026 | Page 9

Regulatory Spotlight clarifications regarding the reciprocal deposit framework to facilitate and simplify compliance. The interim final rule is effective 09/01/2026. Comments are due 10/01/2026. The interim final rule may be viewed at: https://www.govinfo.gov/ content/pkg/FR-2026-09-01/pdf/2026-17865.pdf. Federal Register, Vol. 91, No. 168, 09/01/2026, 56022-56029.

FDIC Updates List of Financial Institutions in Liquidation. FDIC announced it has been appointed the sole receiver for the financial institution listed in the notice. The appointment is effective as of the “date closed” indicated in the listing. The list (as updated from time to time in the Federal Register) may be relied upon as “of record” notice that FDIC has been appointed receiver for purposes of the statement of policy published in the 07/02/1992, issue of the Federal Register. For further information concerning the identification of any institution that have been placed in liquidation, use the website, email, or mailing address provided in the notice. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-27/pdf/2026-17505.pdf. Federal Register, Vol. 91, No. 165, 08/27/2026, 55345.

FDIC Announces Receivership Termination. FDIC, as Receiver, for the insured depository institution listed in the notice, was charged with the duty of winding up the affairs of the former institution and liquidating all related assets. The Receiver has fulfilled its obligations and made all dividend distributions required by law. The Receiver has further irrevocably authorized and appointed FDIC-Corporate as its attorney-in-fact to execute and file any and all documents that may be required to be executed by the Receiver which FDIC-Corporate, in its sole discretion, deems necessary, including but not limited to releases, discharges, satisfactions, endorsements, assignments, and deeds. Effective on the termination date listed in the notice, the Receivership has been terminated, the Receiver has been discharged, and the Receivership has ceased to exist as a legal entity. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-09-03/pdf/2026-18049.pdf. Federal Register, Vol. 91, No. 170, 09/03/2026, 56653. nt.

FDIC Announces Intent to Terminate Receiverships.

Notice is hereby given that FDIC, as Receiver, for the institutions listed in the notice, intends to terminate its receivership for said institutions. The liquidation of the assets for each 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 receiverships will serve no useful purpose. Consequently, notice is given that the receiverships 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 any of the receiverships, such comment must be made in writing, identify the receivership to which the comment pertains, and be sent within thirty days of the date of the notice to the address within the notice. The notice may be viewed at: https:// www.govinfo.gov/content/pkg/FR-2026-09-03/pdf/2026-18050.pdf. Federal Register, Vol. 91, No. 170, 09/03/2026, 56653-56654.

FDIC Extends Comment Period for Disclosure of Information Proposal. FDIC announced an extension of the comment period on the proposed rule, Disclosure of Information, which was published in the Federal Register 06/30/2026. FDIC extended the comment period from 08/31/2026 to 10/05/2026, to provide parties additional time to analyze the proposal and prepare comments. Comments are due 10/05/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-28/pdf/2026-17649.pdf. Federal Register, Vol. 91, No. 166, 08/28/2026, 55501.

FDIC Seeks Comment on Information Collections. FDIC seeks comment regarding two information collections titled, Insurance Sales Consumer Protections and Reverse Mortgage Products. The collections are used as described in the notice. Comments are due 10/08/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-09-08/pdf/2026-18258.pdf. Federal Register, Vol. 91, No. 172, 09/08/2026, 57149-57150.

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Regulatory Spotlight OCC Proposes Revisions to Supervisory Framework for Issuing MRAs. The Office of the Comptroller of the Currency (OCC) proposes revision to the supervisory framework for the issuance of matters requiring attention (MRAs) in response to violations of laws or regulations and for addressing violations for which OCC does not take an enforcement action or issue an MRA. Comments are due 10/01/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-09-01/pdf/2026-17822.pdf. Federal Register, Vol. 91, No. 168, 09/01/2026, 56074-56080.

OCC Seeks Comment on Information Collections. OCC seeks comment regarding an information collection titled, Conversions from Mutual to Stock Form. Under the Home Owners’ Loan Act, a savings association may convert from a mutual form to a stock form, in accordance with the regulations issued by OCC. The regulations set forth the processes, procedures, and required filings in conjunction with both standard mutual-to-stock conversions and voluntary supervisory mutual-to-stock conversions. Comments are due 10/13/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-13/pdf/2026-16532.pdf. Federal Register, Vol. 91, No. 155, 08/13/2026, 52398-52402. OCC seeks comment regarding an information collection titled, Supervisory Guidance: Supervisory Review Process of Capital Adequacy (Pillar 2) Related to the Implementation of the Basel II Advanced Capital Framework. In 2008, OCC and the other federal banking supervisory agencies issued guidance to assist banking organizations in implementing the supervisory review process, or Pillar 2, of the advanced approaches risk-based capital rule. Information collections are part of the guidance as described in the notice. Comments are due 10/08/2026. The notice may be viewed at: https:// www.govinfo.gov/content/pkg/FR-2026-09-08/pdf/2026-18259.pdf. Federal Register, Vol. 91, No. 172, 09/08/2026, 57211-57212.

HUD Announces Changes to Debenture Interest Rates. The Department of Housing and Urban Development (HUD) announced changes in the interest rates to be paid on debentures issued with respect to a loan or mortgage insured by the Federal Housing Administration under the provisions of the National Housing Act. The interest rate for debentures issued under Section 221(g)(4) of the Act during the 6-month period beginning 01/01/2026, is 4 percent. The interest rate for debentures issued under any other provision of the Act is the rate in effect on the date that the commitment to insure the loan or mortgage was issued, or the date that the loan or mortgage was endorsed (or initially endorsed if there are two or more endorsements) for insurance, whichever rate is higher. The interest rate for debentures issued under these other provisions with respect to a loan or mortgage committed or endorsed during the 6-month period beginning 01/01/2026, is 4 ¾ percent. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-21/pdf/2026-17051.pdf. Federal Register, Vol. 91, No. 161, 08/21/2026, 54363-54365.

HUD Issues FY 2026 Funding Awards Allocation Notice. The Housing and Economic Recovery Act of 2008 (HERA) established the Housing Trust Fund (HTF) to be administered by HUD. Pursuant to the Federal Housing Enterprises Financial Security and Soundness Act, as amended by HERA, eligible HTF grantees are the 50 states, the District of Columbia, the Commonwealth of Puerto Rico, American Samoa, Guam, the Commonwealth of Northern Mariana Islands, and the United States Virgin Islands. The notice announced the formula allocation amount for each eligible HTF grantee for fiscal year (FY) 2026. The notice may be viewed at: https:// www.govinfo.gov/content/pkg/FR-2026-09-04/pdf/2026-18163.pdf. Federal Register, Vol. 91, No. 171, 09/04/2026, 56897-56898.

HUD Seeks Comment on Nonprofit Application for FHA-Mortgage Insurance Programs. HUD seeks comment regarding an information collection titled, Nonprofit Application and Recertification for FHAMortgage Insurance Programs. Nonprofit organizations may seek HUD approval to participate in the Federal Housing Administration’s (FHA) nonprofit programs. Nonprofits participating in the programs must provide housing opportunities for low- to moderate-income individuals or families. As part of approval requirements, nonprofits must submit information about the organizational structure, experience, operations, Board of Directors and staff, and financial capabilities of the entity. HUD uses the information to assess the nonprofit’s capacity for carrying out its mission relative to the HUD September 2026 | Page 11

Regulatory Spotlight programs in which it seeks to participate. Comments are due 10/26/2026. The notice may be viewed at: https://www. govinfo.gov/content/pkg/FR-2026-08-25/pdf/2026-17291.pdf. Federal Register, Vol. 91, No. 163, 08/25/2026, 5487954880.

FEMA Issues Final Flood Hazard Determinations. The Federal Emergency Management Agency (FEMA) made flood hazard determinations, which may include additions or modifications of Base Flood Elevations (BFEs), base flood depths, Special Flood Hazard Area (SFHA) boundaries or zone designations, or regulatory floodways on the Flood Insurance Rate Maps (FIRMs) and where applicable, in the supporting Flood Insurance Study (FIS) reports final for communities in Wisconsin. The FIRM and FIS report are the basis of the floodplain management measures that a community is required either to adopt or to show evidence of having an effect in order to qualify or remain qualified for participation in the National Flood Insurance Program (NFIP). The date of 12/10/2026, has been established for the FIRM and, where applicable, the supporting FIS report showing the new or modified flood hazard information for each community. The notice may be viewed at: https://www.govinfo.gov/content/ pkg/FR-2026-08-21/pdf/2026-17078.pdf. Federal Register, Vol. 91, No. 161, 08/21/2026, 54340-54342.

FEMA Issues Final Changes in Flood Hazard Determinations. New or modified Base (1-percent annual chance) Flood Elevations (BFEs), base flood depths, Special Flood Hazard Area (SFHA) boundaries or zone designations, and/or regulatory floodways (hereinafter referred to as flood hazard determinations) as shown on the indicated Letter of Map Revision (LOMR) have been made final for communities in Illinois and Indiana, as listed in the table in the notice. Each LOMR revises the Flood Insurance Rate Maps (FIRMs), and in some cases the Flood Insurance Study (FIS) reports, currently in effect for the listed communities. Each LOMR was finalized as indicated in the table in the notice. The final notice may be viewed at: https://www.govinfo.gov/content/pkg/ FR-2026-08-21/pdf/2026-17071.pdf. Federal Register, Vol. 91, No. 161, 08/21/2026, 54345-54347. New or modified Base (1-percent annual chance) Flood Elevations (BFEs), base flood depths, Special Flood Hazard Area (SFHA) boundaries or zone designations, and/or regulatory floodways (hereinafter referred to as flood hazard determinations) as shown on the indicated Letter of Map Revision (LOMR) have been made final for communities in Indiana and Wisconsin, as listed in the table in the notice. Each LOMR revises the Flood Insurance Rate Maps (FIRMs), and in some cases the Flood Insurance Study (FIS) reports, currently in effect for the listed communities. Each LOMR was finalized as indicated in the table in the notice. The final notice may be viewed at: https://www.govinfo.gov/content/pkg/ FR-2026-08-21/pdf/2026-17070.pdf. Federal Register, Vol. 91, No. 161, 08/21/2026, 54359-54362.

FEMA Issues Notice of Changes in Flood Hazard Determinations. FEMA issued a notice which lists communities in Indiana and Wisconsin, where the addition or modification of Base Flood Elevations (BFEs), base flood depths, Special Flood Hazard Area (SFHA) boundaries or zone designations, or the regulatory floodway (hereinafter referred to as flood hazard determinations), as shown on the Flood Insurance Rate Maps (FIRMs), and where applicable, in the supporting Flood Insurance Study (FIS) reports is appropriate because of new scientific or technical data. The FIRM, and where applicable, portions of the FIS report, have been revised to reflect the flood hazard determinations through issuance of a Letter of Map Revision (LOMR), in accordance with federal regulations. The flood hazard determinations will be finalized on the dates listed in the table in the notice and revise the FIRM panels and FIS report in effect prior to the determination for the listed communities. From the date of the second publication of notification of the changes in a newspaper of local circulation, any person has 90 days in which to request through the community that the Deputy Associate Administrator for Insurance and Mitigation reconsider the changes. The flood hazard determination information may be changed during the 90-day period. The notice may be viewed at: https://www. govinfo.gov/content/pkg/FR-2026-09-10/pdf/2026-18404.pdf. Federal Register, Vol. 91, No. 174, 09/10/2026, 5762257627. FEMA issued a notice which lists communities in Iowa, Michigan, Minnesota, and Wisconsin, where the addition or modification of Base Flood Elevations (BFEs), base flood depths, Special Flood Hazard Area (SFHA) boundaries or zone designations, or the regulatory floodway (hereinafter referred to as flood hazard determinations), as shown on the Flood Insurance Rate Maps (FIRMs), and where applicable, in the supporting Flood Insurance Study (FIS) reports is appropriate because of new scientific or technical data. The FIRM, and where applicable, portions of the FIS report, have been revised to reflect the flood hazard determinations through issuance of a Letter of Map Revision (LOMR), in accordance with Page 12 | September 2026

Regulatory Spotlight federal regulations. The flood hazard determinations will be finalized on the dates listed in the table in the notice and revise the FIRM panels and FIS report in effect prior to the determination for the listed communities. From the date of the second publication of notification of the changes in a newspaper of local circulation, any person has 90 days in which to request through the community that the Deputy Associate Administrator for Insurance and Mitigation reconsider the changes. The flood hazard determination information may be changed during the 90-day period. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-09-10/pdf/2026-18405.pdf. Federal Register, Vol. 91, No. 174, 09/10/2026, 57637-57642.

FinCEN Issues Recordkeeping and Reporting Requirements Orders. The Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order, requiring banks and money transmitters located in the Counties of Hennepin and Ramsey, Minnesota to retain and report records of certain payments of $3,000 or more. The order is effective 08/11/2026. The order may be viewed at: https://www.govinfo.gov/content/pkg/ FR-2026-08-11/pdf/2026-16365.pdf. Federal Register, Vol. 91, No. 153, 08/11/2026, 51588-51590. FinCEN issued a Geographic Targeting Order, requiring certain money services businesses along the southwest border of the United States to report and retain records of transactions in currency of $1,000 or more, but not more than $10,000, and to verify the identity of persons presenting such transactions. The order is effective 09/03/2026. The order may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-09-04/pdf/2026-18194.pdf. Federal Register, Vol. 91, No. 171, 09/04/2026, 56776-56778.

FinCEN Revises Beneficial Ownership Information Reporting Requirements. FinCEN adopted as final, with certain limited changes, the interim final rule issued 03/26/2025, which narrowed beneficial ownership information (BOI) reporting requirements under regulations that implement the Corporate Transparency Act (CTA). The final rule continues to exempt reporting companies from having to report BOI of U.S. person beneficial owners and U.S. person beneficial owners from having to provide BOI to reporting companies; it also exempts reporting companies from having to submit information about their U.S. person company applicants to FinCEN and exempts U.S. person company applicants from any obligation to provide their information. In addition, the final rule exempts all U.S. persons from the requirement to update information already provided to FinCEN in connection with obtaining a FinCEN identifier. The final rule is effective 08/14/2026. The final rule may be viewed at: https://www.govinfo. gov/content/pkg/FR-2026-08-14/pdf/2026-16576.pdf. Federal Register, Vol. 91, No. 156, 08/14/2026, 52508-52528.

FinCEN Seeks Comment on Special Measure Regarding Banque Misr UAE. FinCEN issued a proposed rule, pursuant to section 311 of the USA PATRIOT Act, that finds the five United Arab Emirates-based branches of Banque Misr (collectively, Banque Misr UAE) to be of primary money laundering concern and proposed imposing a special measure to: prohibit U.S. financial institutions from opening or maintaining a correspondent account for, or on behalf of, Banque Misr UAE; require U.S. financial institutions to take reasonable steps not to process a transaction for the correspondent account in the U.S. of a foreign banking institution if such a transaction involves Banque Misr UAE; and require U.S. financial institutions to apply special due diligence to their foreign correspondent accounts that are reasonably designed to guard against their use to process transactions involving Banque Misr UAE. Comments are due 10/01/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-09-01/ pdf/2026-17871.pdf. Federal Register, Vol. 91, No. 168, 09/01/2026, 56085-56095.

Treasury Proposes GENIUS Act Regulations. The Department of the Treasury (Treasury) issued a proposed rule to implement section 3 of the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act regarding the statutory prohibitions and limitations on payment stablecoin issuance, offer, and sale in the United States. Comments are due 10/19/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-18/pdf/2026-16796.pdf. Federal Register, Vol. 91, No. 158, 08/18/2026, 53368-53391.

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Regulatory Spotlight Treasury Seeks Comment on MSB Registration Form. Treasury seeks comment regarding an information collection titled, Registration of Money Services Businesses, FinCEN Form 107. Comments are due 09/21/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-202608-21/pdf/2026-17091.pdf. Federal Register¸ Vol. 91, No. 161, 08/21/2026, 54440-54441.

IRS Issues Final Car Loan Interest Deduction Rule. The Internal Revenue Service (IRS) issued a final rule regarding the deduction for certain taxpayers for an amount up to $10,000 of qualified passenger vehicle loan interest. The final rule also includes rules regarding new information reporting requirements for certain persons who, in a trade or business, receive from any individual interest aggregating $600 or more for any calendar year on a specified passenger vehicle loan, including applicable penalties for failures to file information returns or furnish payee statements as required. The final rule is effective 11/09/2026. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-09-08/pdf/2026-18219.pdf. Federal Register, Vol. 91, No. 172, 09/08/2026, 57214-57244.

IRS Issues Inflation Adjustment Factor for Clean Electricity Production Credit. IRS published the 2026 inflation adjustment factor and applicable amounts used in calculating the amount of the clean electricity production credit allowable under section 45Y of the Internal Revenue Code. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-09-04/pdf/2026-18105.pdf. Federal Register, Vol. 91, No. 171, 09/04/2026, 56942.

IRS Issues Proposed Rules Affecting Trump Accounts. IRS issued a proposed rule to provide guidance with respect to employer contributions to Trump accounts, including applicable nondiscrimination rules, and the nondiscrimination rules for dependent care assistance programs. The proposed rule would affect employers maintaining a Trump account contribution program or a dependent care assistance program and employees participating in the programs. Comments are due 09/25/2026. IRS also issued a correction to the proposed rule. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-11/pdf/202616314.pdf. Federal Register, Vol. 91, No. 153, 08/11/2026, 51611-51633. The correction may be viewed at: https:// www.govinfo.gov/content/pkg/FR-2026-08-24/pdf/C1-2026-16314.pdf. Federal Register, Vol. 90, No. 162, 08/24/2026, 54686. IRS issued a proposed rule to provide guidance regarding eligible investments, which are the only assets in which Trump account funds may be invested before the first day of the calendar year in which the account beneficiary attains age 18. Comments are due 10/20/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-202608-21/pdf/2026-17123.pdf. Federal Register, Vol. 91, No. 161, 08/21/2026, 54280-54295.

IRS Issues Proposed Rule on Foreign Currency Gain or Loss of Controlled Foreign Corporations. IRS issued a proposed rule relating to the determination and recognition of foreign currency gain or loss with respect to qualified business units (QBUs) of controlled foreign corporations (CFCs). The proposed rule provides an election under which a CFC generally would not be required to compute or recognize foreign currency gain or loss upon a remittance from a QBU, except in connection with certain in-bound non-recognition transactions. Comments are due 11/12/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-14/pdf/2026-16569.pdf. Federal Register, Vol. 91, No. 156, 08/14/2026, 52553-52576.

IRS Proposes Reporting Requirement Removal for Trusts Whose Charitable Contribution Deductions Are Solely for Contributions Made by Pass-through Entities. IRS issued a proposed rule to amend regulations that require certain trusts to report all charitable contributions and amounts permanently set aside for a charitable purpose on Form 1041-A, U.S. Information Return Trust Accumulation of Charitable Amounts. The proposed rule would remove the reporting requirement for these trusts with respect to taxable years in which the trust’s only claimed charitable contribution deduction results from a charitable entity in which the trust Page 14 | September 2026

Regulatory Spotlight owns an interest. The proposed rule would also modify existing regulations to clarify that split-interest trusts satisfy their filing obligations by filing Form 5227, Split-Interest Trust Information Return, rather than Form 1041-A. Comments are due 10/16/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-17/pdf/202616769.pdf. Federal Register, Vol. 91, No. 157, 08/17/2026, 53217-53221.

IRS Issues Proposed Rule on Income Rules Related to Sale or Other Disposition of Property. IRS issued a proposed rule regarding section 250 of the Internal Revenue Code (Code) to provide guidance on certain income of a domestic corporation that is excluded in the determination of deduction eligible income. The category of income consists of income and gain from the sale or other disposition of intangible property and any other property of a type that is subject to depreciation, amortization, or depletion. Comments are due 10/05/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-20/pdf/2026-17019.pdf. Federal Register, Vol. 91, No. 160, 08/20/2026, 53792-53803.

IRS Issues Proposed Rule Affecting Single-Employer Defined Benefit Plans. IRS issued a proposed rule that would modify rules relating to the minimum funding requirement applicable to singleemployer defined benefit pension plans. The modifications include changes to the rules relating to the determination of a plan’s target normal cost and funding target and would implement certain statutory amendments that have not yet been reflected in the regulations. Comments are due 10/19/2026. The proposed rule may be viewed at: https://www.govinfo. gov/content/pkg/FR-2026-08-20/pdf/2026-17021.pdf. Federal Register, Vol. 91, No. 160, 08/20/2026, 53803-53811.

IRS Seeks Comment on Tax Return Forms. IRS seeks comment regarding an information collection titled, U.S. Individual Income Tax Returns and Related Forms, Schedules, Attachments, and Published Guidance. The forms, schedules, and attachments are used by individuals to report income tax liability. There have been changes in regulatory guidance related to various forms in the information collection. Comments are due 10/26/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-202608-25/pdf/2026-17292.pdf. Federal Register, Vol. 91, No. 163, 08/25/2026, 54920-54925.

SBA Removes Social Disadvantage Presumption from 8(a) Program. The Small Business Administration (SBA) amended its Section 8(a) Business Development Program (8(a) BD program). The final rule applies only to the 8(a) BD eligibility of small businesses owned and controlled by individuals. It does not amend or affect the eligibility of entity-owned small businesses (i.e., those owned by tribes, Alaska Native Corporations, Native Hawaiian Organizations, or Community Development Corporations). The final rule removes the rebuttable presumption that individuals belonging to certain designated groups are socially disadvantaged and sets forth revised standards for individuals establishing social disadvantage. The final rule is effective 09/10/2026. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-11/pdf/2026-16370.pdf. Federal Register, Vol. 91, No. 153, 08/11/2026, 51568-51573.

SBA Rescinds Unnecessary Notice and Comment Procedures. SBA rescinded its policy of engaging in notice and comment rulemaking even where the Administrative Procedure Act does not require notice and comment rulemaking. As a result, SBA will follow the default requirements of the Administrative Procedure Act. SBA reserves the right to engage in voluntary notice and comment rulemaking even where not required by the Administrative Procedure Act as a matter of policy on a case-by-case basis. The final rule is effective 08/31/2026. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-31/pdf/2026-17731. pdf. Federal Register, Vol. 91, No. 167, 08/31/2026, 55737-55738.

SBA Issues List of Requests from States or Tribes for SBA Disaster Declaration. SBA provided an updated list of requests received to make a disaster declaration for a state, territory, or Tribe. The list complies with a directive in the explanatory statement of the Consolidated Appropriations Act. The list was issued 08/07/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-11/pdf/2026-16349.pdf. Federal Register, Vol. 91, No. 153, 08/11/2026, 51822-51823. September 2026 | Page 15

Regulatory Spotlight SBA Announces Revised Size Standards Methodology. SBA announced revision of its white paper that explains how SBA establishes, reviews, and modifies small business size standards. The revised white paper provides a detailed description of SBA’s size standards methodology, including changes from its 2024 methodology. Comments are due 09/21/2026. The notice may be viewed at: https://www.govinfo. gov/content/pkg/FR-2026-08-20/pdf/2026-17039.pdf. Federal Register, Vol. 91, No. 160, 08/20/2026, 54096-54210.

SBA Issues Proposed Rule on Small Business Size Standards. SBA proposed to adjust size standards for 338 industry groups and industries identified in the proposed rule. The new size standards are designed to better reflect the nature of the markets in which small businesses compete. Comments are due 09/21/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-20/pdf/202617042.pdf. Federal Register, Vol. 91, No. 160, 08/20/2026, 53741-53784.

FSA Implements Permanent Application Fast Track Process. The Farm Service Agency (FSA) issued a final rule to amend the Farm Loan Program (FLP) regulations to permanently implement the Application Fast Track (AFT) process, which expedites underwriting for certain direct loan applicants by using financial benchmarks and historical repayment data to identify applicants least likely to default. The final rule also includes regulatory changes intended to improve program efficiency and support IT modernization efforts consisting of minor policy changes, clarifications, and technical corrections. The final rule is effective 10/01/2026. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-09-04/pdf/2026-18164.pdf. Federal Register, Vol. 91, No. 171, 09/04/2026, 56741-56775.

FSA Implements Plan of Emergency Relief Program. FSA announced how it will implement a provision of the Full-Year Continuing Appropriations and Extensions Act 2025, to allow producers who, in certain circumstances would need to repay Emergency Relief Program 2022 payments, to retain those payments, not to exceed 90 percent of the producer’s revenue losses, if a de minimis amount of a producer’s revenue loss is attributable to crops that were not insured or covered under the Noninsured Crop Disaster Assistance Program. Through the notice, FSA has defined “de minimis.” The notice may be viewed at: https://www.govinfo.gov/ content/pkg/FR-2026-08-14/pdf/2026-16661.pdf. Federal Register, Vol. 91, No. 156, 08/14/2026, 52664-52666.

FCA Confirms Final Rule Effective Date That Removed TDRs from Loan Performance Categories and Financial Reporting. The Farm Credit Administration (FCA) confirmed the effective date of the final rule that amended FCA regulatory highrisk loan performance categories by removing “formally restructured loans,” also known as troubled debt restructurings (TDR). The final rule provided the rule 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 final rule is 08/24/2026. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-0826/pdf/2026-17440.pdf. Federal Register, Vol. 91, No. 164, 08/26/2026, 54947.

Agencies Propose to Rescind Construction and Repair Regulation. The Rural Business-Cooperative Service (RBC), Rural Housing Service (RHS), and Rural Utilities Service (RUS) (collectively, the agencies) issued a proposed rule to rescind the regulation regarding construction and repairs. The agencies found the regulation to be unnecessary and unduly burdensome. In addition, the proposed rule makes changes to remove references to the construction and repair regulation. Comments are due 10/19/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-19/pdf/2026-16914.pdf. Federal Register, Vol. 91, No. 159, 08/19/2026, 53540-53542.

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Regulatory Spotlight Agencies Seek Comment on RD Loan Modernization Information Collection. The Rural Business Cooperative Service (RBC), Rural Housing Service (RHS), and Rural Utilities Service (RUS) (collectively, the agencies) seek comment regarding an information collection titled, Rural Development (RD) Loan Modernization Initiative. The agencies launched the transformation of its loan and grant systems that support farmers, ranchers, and rural communities into one modern platform. The platform will manage all current active files in one place, enabling employees to deliver faster service to customers and lending partners. To further improve customer experience and service delivery for applicants, the agencies are developing an Online Loan Application for the applicants to submit requests for Direct Loan assistance electronically. Future releases and iterations of the online application software will include expansion of functionality for direct loans, guarantees, grant making, and provide the ability for primary loan servicing application submission. Comments are due 11/03/2026. The notice may be viewed at: https://www.govinfo. gov/content/pkg/FR-2026-09-04/pdf/2026-18173.pdf. Federal Register, Vol. 91, No. 171, 09/04/2026, 56833-56834.

Agencies Extend Compliance Date for Form PF Amendments. The Commodity Futures Trading Commission (CFTC) and Securities and Exchange Commission (SEC) (collectively, the agencies) issued a final rule to further extend the compliance date for the amendments to Form PF that were adopted 02/08/2024, from 10/01/2026, to 07/01/2027. Form PF is the confidential reporting form for certain SEC-registered investment advisers to private funds, including those that also are registered with CFTC as a commodity pool operator or a commodity trading adviser. The effective date for the release is 09/03/2026. The final rule may be viewed at: https:// www.govinfo.gov/content/pkg/FR-2026-09-03/pdf/2026-18104.pdf. Federal Register, Vol. 91, No. 170, 09/03/2026, 56593-56596.

CFTC Proposes Amendments to Registration of CPOs and CTAs. CFTC proposed several amendments to its registration of pool operators (CPOs) and commodity trading advisors (CTAs) to reduce duplicative and overlapping regulation and reflect inflation. The proposal would add an exemption from CPO registration for certain investment advisers registered with the Securities and Exchange Commission in relation to commodity pools for which the participants are limited to certain sophisticated investors and which meet other conditions; add a related registration exemption for CTAs; and increase the total gross capital contributions threshold in the CPO registration exemption for small commodity pools to account for inflation. CFTC preliminarily intends for the proposed rule, if adopted, to supersede certain no-action positions issued by its Market Participants Division. Comments are due 10/05/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-21/ pdf/2026-17079.pdf. Federal Register, Vol. 91, No. 161, 08/21/2026, 54264-54280.

CFTC Proposes to Amend Swap Execution Facilities Regulation. CFTC issued a proposed rule to amend its regulations for swap execution facilities (SEF) to remove the requirement for SEFs to offer an order book for swap transactions that are not subject to trade execution requirement under section 2(h) (8) of the Commodity Exchange Act. These types of swap transactions are referred to in CFTC regulations as “permitted transactions.” Comments are due 09/25/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/ pkg/FR-2026-08-26/pdf/2026-17416.pdf. Federal Register, Vol. 91, No. 164, 08/26/2026, 55030-55037.

CFTC Seeks Comment on Information Collections. CFTC seeks comment regarding an information collection titled, Rules Relating to the Operations and Activities of Commodity Pool Operators (CPOs) and Commodity Trading Advisors (CTAs) and to Monthly Reporting by Futures Commission Merchants. The Commodity Exchange Act (CEA) authorizes CFTC to require CPOs and CTAs to maintain books and records and to file reports as required. The information collections are necessary as further explained in the notice. Comments are due 10/13/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-202608-14/pdf/2026-16631.pdf. Federal Register, Vol. 91, No. 156, 08/14/2026, 52677-52678. CFTC seeks comment regarding an information collection titled, Part 41, Relating to Security Futures Products. Section 4d(c) of the Commodity Exchange Act (CEA) requires CFTC to consult with the Securities and Exchange Commission (SEC) and issue such rules, regulations, or orders as are necessary to avoid duplicative or conflicting regulations September 2026 | Page 17

Regulatory Spotlight applicable to firms that are fully registered with SEC as brokers or dealers and CFTC as futures commission merchants involving provisions of the CEA that pertain to the treatment of customer funds. The rules associated with the information collection include registration, reporting requirements, recordkeeping requirement, and third-party disclosure requirements as explained in the notice. Comments are due 10/19/2026. The notice may be viewed at: https://www. govinfo.gov/content/pkg/FR-2026-08-19/pdf/2026-16876.pdf. Federal Register, Vol. 91, No. 159, 08/19/2026, 5361053611.

SEC Issues Proposed Crypto Assets Regulation. SEC issued a proposed rule to create a tailored offering regime for certain investment contracts involving crypto assets. The proposed rule is intended to facilitate capital formation and accommodate innovation within the crypto asset markets while ensuring that investors are adequately protected and provided with the information they need to make informed investment decisions. The proposed rule would be set forth in a new regulation titled, Regulation Crypto Assets, and would include two exemptions from the registration requirements of section 5 of the Securities Act. The first exemption would permit offerings of up to $5 million during a four-year period. The second exemption would permit offerings of up to $75 million during each 12-month period. Under both exemptions, issuers would be required to make certain principles-based narrative disclosures available to their investors. In addition, issuers under the second exemption would be required to provide financial statements and would be subject to ongoing reporting requirements. Issuers that rely on the exemptions would remain subject to the anti-fraud and anti-manipulation provisions of the Federal securities laws. The proposed rule also would include a conditional safe harbor from the term “investment contract” in the definition of “security” in the Securities Act and the Securities Exchange Act. If the conditions of that proposed safe harbor are satisfied, a crypto asset would be deemed not to be subject to an investment contract for purposes of the definitions of “security.” Comments are due 10/20/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/ FR-2026-08-21/pdf/2026-17183.pdf. Federal Register, Vol. 91, No. 161, 08/21/2026, 54510-54655.

SEC Proposes Amendments to Transfer Agent Rule. SEC proposes to adopt new rules, amend existing rules, amend the existing form for registration as a transfer agent and the existing form for reporting activities of transfer agents, and rescind an existing rule governing registered transfer agents. The proposed rule is designed to modernize the rules governing registered transfer agents. Comments are due 11/03/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-09-04/pdf/202618190.pdf. Federal Register, Vol. 91, No. 171, 09/04/2026, 56946-57061.

SEC Proposes to Rescind Political Contributions Rule. SEC proposes to rescind the political contribution rule under the Investment Advisers Act, which prohibits investment advisers from providing investment advisory services for compensation to a government client for two years after an adviser or any covered associate of the adviser makes a contribution to certain categories of elected officials or candidates, among other prohibitions. SEC stated it is of the view that other requirements of the Investment Advisers Act and its associated rules, including prohibitions on fraud, fiduciary duty requirements, compliance rule, and code of ethics rule (defined in the proposed rule), are likely sufficient to address pay-to-play practices while allowing an adviser the flexibility to implement an approach that is more appropriately tailored to its particular risks, rendering the political contribution rule unnecessary. SEC also proposed to amend the rule under the Investment Advisers Act pertaining to books and records consistent with the proposed rescission. Comments are due 11/09/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-09-10/pdf/2026-18424.pdf. Federal Register, Vol. 91, No. 174, 09/10/2026, 57698-57726.

FTC Updates National Do Not Call Registry Fees. The Federal Trade Commission (FTC) amended its Telemarketing Sales Rule (TSR) to update the fees charged to entities accessing the National Do Not Call Registry as required by the Do Not Call Registry Fee Extension Act. The revised fees are effective 10/01/2026. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-26/ pdf/2026-17428.pdf. Federal Register, Vol. 91, No. 164, 08/26/2026, 54947-54948.

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Regulatory Spotlight FTC Seeks Comment on Franchise Rule Information Collection. FTC seeks comment regarding an information collection titled, Franchise Rule, 16 CFR part 436. The rule ensures that consumers who are considering a franchise investment have access to the material information they need to make an informed investment decision and compare different franchise offerings as explained in the notice. Comments are due 09/17/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-18/pdf/2026-16827.pdf. Federal Register, Vol. 91, No. 158, 08/18/2026, 53415-53416.

FCC Proposes to Improve Effectiveness of Robocall Mitigation Database. The Federal Communications Commission (FCC) proposed steps to strengthen the reliability, integrity, and effectiveness of the Robocall Mitigation Database (Database) as a core component of its illegal-call prevention framework. FCC proposed measures aim to ensure that Database filings are accurate, complete, and current, and to safeguard the Database so that only legitimate, transparent, and accountable providers may enter or remain listed. Additionally, FCC proposed new tools to prevent bad actors and noncompliant providers from accessing or remaining in the Database, including strengthened screening procedures for new filers, improved mechanisms for identifying noncompliant providers, expedited removal processes, and safeguards to prevent unauthorized re-entry into the Database. Comments are due 10/09/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-09-09/pdf/202618366.pdf. Federal Register, Vol. 91, No. 173, 09/09/2026, 57454-57489.

VA Seeks Comment on Information Collection. The Department of Veterans Affairs (VA) seeks comment regarding an information collection titled, Application for Assumption Approval and/or Release from Personal Liability to the Government on a Home Loan. The application is completed by Veterans who are selling their homes by assumption rather than requiring purchasers to obtain their own financing to pay off the loan. The data furnished is essential to determinations for assumption approval, release of liability, and substitution of entitlement. Comments are due 10/13/2026. The notice may be viewed at: https:// www.govinfo.gov/content/pkg/FR-2026-08-13/pdf/2026-16501.pdf. Federal Register, Vol. 91, No. 155, 08/13/2026, 52403.

Compliance Notes FinCEN, jointly with FRB, FDIC, OCC, and NCUA, released three FAQs regarding the treatment of verifiable digital credentials (VDCs) under CIP. The resource addresses the use of state-issued mobile driver’s licenses (mDLs) and other government-issued VCDs, which may be used to verify identities of natural person customers under the BSA CIP rule. The FAQs explain how the CIP rule may apply to such VDCs. Additionally, the agencies are amending a previously issued FAQ to reflect updated terminology being used to describe VDCs. The answers to the FAQs neither alter existing BSA legal or regulatory requirements nor establish new supervisory expectations. The VDC-related FAQs may be viewed at: https://www.fincen.gov/system/files/2026-09/MDL-VDC-FAQs.pdf FTC issued a Consumer Alert to warn about a scam targeting farmers. Scammers pose as farm equipment businesses selling “fake” equipment to farmers, who end up empty-handed. Farmers are finding advertisements on social media for farm equipment. When contacted regarding the sale, scammers send a purchase agreement and invoice to the farmer, typically ask the farmer to wire money to purchase the equipment piece, and schedule a delivery date. However, the delivery never comes. It turns out it was never a legitimate business, and the situation was all a scam. The scammers stop answering calls or make other excuses, such as that there was an issue with the delivery truck. The FTC Consumer Alert may be viewed at: https://consumer.ftc.gov/consumer-alerts/2026/09/scammers-are-impersonatingfarm-equipment-businesses Fannie and Freddie announced the expansion of the use of VantageScore 4.0 by all approved lenders. Each GSE guide may be viewed at the following links, respectively, https://capitalmarkets.fanniemae.com/mortgage-backedsecurities/fannie-mae-broadens-availability-vantagescore and https://guide.freddiemac.com/app/guide/bulletin/2026-H

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Compliance Notes The Federal Reserve Bank of Philadelphia announced the launch of a new website for the Consumer Compliance Outlook and Outlook Live. The URLs from the legacy website have changed and will not work on the new site. The new website may be viewed at: https://www.consumercomplianceoutlook.org/ FinCEN released a Financial Trends Analysis and an alert to financial institutions to be vigilant to digital asset investment scams perpetrated by overseas scam centers. Digital asset investment scams (also known as pig butchering, romance baiting, or cryptocurrency confidence schemes) are sophisticated fraud operations. Criminals use fake personas and social engineering tactics to manipulate victims, who are often American, into transferring funds to fraudulent digital asset investments. The scams are largely perpetrated by transnational criminal organizations based in Southeast Asia, which operate industrial-scale scam compounds and leverage vast networks of criminal actors to facilitate and profit from scams. The analysis, alert, and other resources may be viewed at: https://www.fincen.gov/news/news-releases/ fincen-identifies-nearly-13-billion-linked-suspected-digital-asset-scams FinCEN also released a Financial Trends Analysis regarding health care fraud activity based upon the analysis of SAR data submitted by financial institutions. The report identified approximately $17.5 billion in suspicious financial activity potentially linked to health care fraud. The report may be viewed at: https://home.treasury.gov/news/press-releases/ sb0625/ FDIC released updates to both its Risk Management Manual of Examination Policies (RMS Manual) and Consumer Compliance Examination Manual. Redlined versions reflecting the updates and entire manuals may be viewed at the following links, respectively: https://www.fdic.gov/risk-management-manual-examination-policies and https:// www.fdic.gov/consumer-compliance-examination-manual IRS posted a notice to remind information return filers who currently use the Filing Information Returns Electronically (FIRE) system to prepare now for the retirement of that system and get ready to transition to the Information Returns Intake System (IRIS) before the 2027 filing season. After the November maintenance window, filers will no longer be able to submit information returns through FIRE. Current FIRE users must transition to IRIS to file tax year 2026 information returns during the 2027 filing season. The reminder may be viewed at: https://www.irs.gov/ newsroom/irs-reminder-information-return-e-file-system-transitioning-to-a-new-platform

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