Final Rules

Key dates

2026-08-27

The FDIC Board unanimously approved the final rule on unsafe or unsound practices and MRAs and the interim final rule on Road to Housing Act reciprocal deposits by notational vote.

Suggested considerations

• Compliance teams may wish to inventory open MRAs, supervisory recommendations, and section 8 enforcement matters and assess whether each matter satisfies the new material-harm, Deposit Insurance Fund risk, prudent-operation, or legal-violation criteria.
• Banks should consider mapping existing policies, procedures, reporting controls, documentation findings, and governance issues to the new distinction between MRAs, supervisory observations, and other violations, while retaining controls for matters that could affect capital, asset quality, earnings, liquidity, market-risk sensitivity, consumer outcomes, or receivership risk.
• Management and board committees may wish to prepare for examiner requests for the objective facts, risk analysis, and reasoning supporting any MRA or unsafe-or-unsound-practice conclusion, including evidence of how the bank assessed reasonably foreseeable conditions.
• Banks using reciprocal deposits should consider recalculating their permissible nonbrokered reciprocal-deposit capacity under the tiered liability formula and updating brokered-deposit classification, liquidity, deposit reporting, internal limits, and regulatory reporting controls.
• Potential agent institutions should verify their eligibility under the revised definition, including the applicable capital and examination-rating requirements and the broadened CAMELS-based criteria.
• Treasury, balance-sheet management, and deposit operations teams may wish to model the effect of the expanded reciprocal-deposit exclusion on funding concentration, liquidity stress assumptions, deposit pricing, and brokered-deposit monitoring.
• Legal and regulatory-affairs teams should monitor the Federal Register publication of both rules, confirm the effective dates, review any interim-final-rule comment opportunity, and determine whether implementation or comments are appropriate.
• Banks should consider reviewing examiner lookback requests and suspicious-activity review scopes against the related OCC examination guidance, which generally limits lookbacks involving failures to detect or report suspicious activity to one year or less unless heightened approval is obtained.

What changed

The final supervisory rule defines an unsafe or unsound practice as a practice, act, or failure to act that is contrary to generally accepted standards of prudent operation and that, if continued, is likely to materially harm the bank's financial condition or present a material risk of loss to the Deposit Insurance Fund, or that has materially harmed the bank's financial condition.

Key dates

2026-08-14

Effective date of FinCEN final rule "Beneficial Ownership Information Reporting Requirement Revision" (91 FR 52508; RIN 1506-AB67), permanently narrowing CTA BOI reporting to foreign reporting companies and codifying exemptions for U.S. persons and domestic reporting companies.

Suggested considerations

• Compliance teams at foreign reporting companies should review the revised 31 CFR 1010.380 definition of "reporting company" and confirm that their entity meets the narrowed criteria (foreign formation plus registration to do business in a U.S. State or Tribal jurisdiction), updating BOI reporting inventories and scoping accordingly.
• Foreign reporting companies should update BOI reporting procedures to ensure that reports capture beneficial owners who are non-U.S. persons while excluding U.S. person beneficial owners, including revising data collection forms, internal instructions, and system logic to avoid collecting or transmitting U.S. person BOI under the CTA framework.
• Firms involved in foreign pooled investment vehicles registered in the United States may wish to revise governance and reporting processes so that BOI reports for such vehicles identify only the individual exercising substantial control (or greatest authority over strategic management) who is not a U.S. person, and cease including U.S. controllers where they qualify as U.S. persons.
• Corporate secretarial and entity management functions should update CTA/BOI scoping matrices to remove domestic corporations, LLCs, and similar entities from BOI reporting obligations and to reflect that only qualifying foreign entities remain in scope, while maintaining awareness of other AML and KYC obligations that may still apply independently of the CTA.
• Onboarding and registration workflows for foreign entities should be reviewed so that BOI reporting triggers, timelines, and responsibilities are aligned with the final rule’s foreign-only scope, including any remaining deadlines tied to registration dates, and that staff understand that U.S. person company applicant information is no longer required for CTA reporting.
• Firms maintaining records of U.S. person beneficial owners and company applicants for CTA purposes may wish to reassess retention policies, ensuring that any continued collection or storage of such data is for other legal or risk-management purposes rather than CTA compliance, and that privacy notices and data minimization practices reflect the updated regulatory position.
• Compliance teams should revise CTA-related policies, procedures, and training materials to incorporate the exemptions for U.S. persons holding FinCEN IDs, clarifying that these individuals are no longer required to update or correct BOI previously provided to obtain the identifier, and documenting any residual obligations under other BSA or AML rules.
• Banks, broker-dealers, and other AML-regulated firms should consider the impact of reduced BOI availability for U.S. persons on their own customer due diligence, beneficial ownership, and risk assessment frameworks, and evaluate whether internal KYC standards or other regulatory requirements (such as customer due diligence rules) necessitate separate collection of U.S. person ownership information irrespective of FinCEN’s CTA exemptions.

What changed

The definition and scope of "reporting company" under 31 CFR 1010.380, as implemented under 31 U.S.C. 5336, are now permanently narrowed so that entities previously defined as domestic reporting companies are exempt from BOI reporting requirements, including initial, updated, and corrected BOI reports. Foreign reporting companies remain subject to BOI reporting, but the rule confirms that they are exempt from reporting beneficial ownership information for any U.S. person beneficial owners; those U.S.

Key dates

2026-08-11

Effective date of the Geographic Targeting Order

2027-02-06 Deadline

Order period ends after 180 days unless renewed

Suggested considerations

• Compliance teams may wish to identify all branches, subsidiaries, and offices in Hennepin and Ramsey Counties and map which payment flows meet the Order’s definition of a Covered Transaction.
• Firms may wish to update transaction-monitoring and customer due diligence workflows to capture the additional data elements required for bank or money transmitter reports, including beneficiary or recipient contact details and government-benefits-related funding questions.
• Operational teams may wish to confirm readiness to submit reports through the FI Portal and to generate the required CSV files using the Minnesota Fraud GTO template and naming convention.
• Records-management teams may wish to set a retention control ensuring all reports and related compliance records are preserved for five years from the last day the Order is effective.
• Banks and money transmitters may wish to review whether any existing BSA or sanctions screening processes can be leveraged to identify covered international transfers meeting the $3,000 threshold.
• Compliance teams may wish to test month-end reporting processes so filings occur by the end of the month following the month in which each Covered Transaction took place.

What changed

The Order creates a temporary, geographically targeted recordkeeping and reporting regime under 31 CFR Part 1010 for covered institutions in Hennepin and Ramsey Counties. A “Covered Business” is any bank under 31 CFR 1010.100(d) or money transmitter under 31 CFR 1010.100(ff)(5) with a branch, subsidiary, or office in the covered area.

Key dates

2025-12-29

NCUA published the proposed rule to remove 12 CFR 701.25(b)

2026-02-27 Deadline

Public comment period closed

2026-08-06

Final rule published in the Federal Register at 91 FR 50664

2026-09-08 Deadline

Final rule becomes effective and 12 CFR 701.25(b) is removed

Suggested considerations

• Compliance teams may wish to confirm that internal lending policies still reflect the remaining limits in 12 CFR 701.25(a) and any other applicable provisions, even though the separate policy requirement in paragraph (b) has been removed.
• Boards may wish to review whether any internal approval process for loans to other credit unions remains desirable as a governance control, particularly where state law, bylaws, or enterprise risk practices still support formal approval.
• State-chartered credit unions may wish to verify whether state law or state supervisory expectations still require board approval or written policies for loans to other credit unions.
• Monitoring teams may wish to update regulatory inventories, policy cross-references, and exam prep materials to reflect that 12 CFR 701.25(b) is no longer codified effective 2026-09-08.
• Training and procedure documents may wish to distinguish between the removed board-policy requirement and the continuing statutory and regulatory loan limits that still apply.

What changed

The final rule removes the documentation requirement in 12 CFR 701.25(b) that required board approval of all loans to other credit unions and written policies governing those loans. NCUA states that federal credit unions remain subject to statutory requirements on loans to credit unions, and the remaining limits and requirements in § 701.25 continue to apply. The rule does not change the aggregate loan limit in § 701.25(a), which remains 25% of the lending federal credit union’s paid-in and unimpaired capital and surplus.

Key dates

2026-02-25

NCUA published the proposed rule for public comment.

2026-04-27

Public comment period closed after NCUA received 15 comments.

2026-08-06

NCUA published the final rule in the Federal Register at 91 FR 50680.

2026-09-08 Deadline

Final rule becomes effective.

Suggested considerations

• Compliance teams may wish to review and update FCU written policies for purchases, sales, and pledges of eligible obligations so they no longer mirror the removed prescriptive checklist and instead reflect the board’s own risk-based framework.
• Credit unions may wish to confirm that internal governance documents still address conflicts of interest and compensation consistently with bylaws and fiduciary-duty expectations, even though the detailed regulatory text has been removed.
• Firms should consider updating any procedures, training materials, and control inventories that reference the old paragraph structure or the former 12 CFR 701.23(h) cross-reference.
• Compliance teams may wish to validate that transaction approval, due diligence, documentation, and agreement-review processes continue to be embedded in policy at a level appropriate to the institution’s risk profile, even though the rule is less prescriptive.
• Federal credit unions may wish to brief boards and relevant committees on the shift from a checklist-based rule to a principles-based framework so governance oversight remains aligned with supervisory expectations.

What changed

['The rule removes the mandated lists of items that FCU written policies must address for purchases, sales, and pledges of eligible obligations under 12 CFR 701.23(b)(6), (c), and (d). FCUs still must maintain written policies for these activities, but the regulation no longer prescribes a detailed checklist of required policy contents.', 'The rule removes the detailed conflicts-of-interest and compensation provision formerly in 12 CFR 701.23(g).

Key dates

2026-03-25

NCUA issued the proposed rule to remove the prescriptive requirements

2026-05-26 Deadline

Public comment period closed

2026-08-06

Final rule was published in the Federal Register at 91 FR 50677

2026-09-08 Deadline

Final rule becomes effective

Suggested considerations

• Compliance teams may wish to review current indirect vehicle lending policies to confirm they no longer reference the removed 50% and 100% net-worth limits.
• Boards may wish to document a board-approved risk appetite and concentration framework for third-party serviced indirect vehicle loans.
• Credit unions may wish to align vendor oversight, due diligence, and servicing controls with their internal policies since the prior waiver pathway is no longer the operative framework.
• State-chartered federally insured credit unions may wish to verify any conforming updates needed to insurance-related procedures and governance materials.
• Compliance functions may wish to update training, policy manuals, and examination binders to reflect that supervision will now focus on principles-based oversight rather than the deleted rule text.

What changed

The final rule removes 12 CFR 701.21(h) in full, eliminating the existing concentration limits, the 30-month step-up to a higher limit, the waiver process to a Regional Director, the related response timeline, and the embedded definition framework tied to that paragraph. NCUA also states that it removed the parallel requirement in 12 CFR 741.203(c) and the related citation in 12 CFR 746.201(c), as part of the same deregulatory package.

Key dates

2026-08-06

Federal Register publication of the final rule at 91 FR 50661

2026-09-08 Deadline

Final rule becomes effective

Suggested considerations

• Compliance teams may wish to update policies, procedures, and product templates that still reference the former segregated deposit and collateral formulas in 12 CFR 701.20.
• Institutions may wish to review surety and guaranty programs to ensure the obligation remains fixed in amount and duration and is structured as an otherwise permissible loan under the applicable lending regulations.
• FCUs may wish to confirm that any related lending analysis still addresses member lending limits and other applicable provisions, including where commercial lending rules apply.
• FISCUs may wish to confirm continued state-law authority to act as surety or guarantor and verify any state-specific constraints or approvals before offering these arrangements.
• Risk and compliance functions may wish to reassess collateral practices for these products in light of the new flexibility while preserving safety-and-soundness controls.

What changed

The final rule deletes the specific segregated deposit requirement in 12 CFR 701.20(c)(3) for suretyship and guaranty agreements. It also removes the detailed collateral standards in 12 CFR 701.20(d), including the prior 100 percent and 110 percent collateral categories and the requirement for a perfected security interest tied to those prescribed values.

Key dates

2026-02-25

NCUA issued the proposed rule removing 12 CFR 701.26; public comments were invited through April 27, 2026

2026-04-27 Deadline

Public comment deadline on the proposal

2026-08-06

Final rule published in the Federal Register at 91 FR 50674

2026-09-08 Deadline

Final rule becomes effective

Suggested considerations

• Compliance teams may wish to remove references to 12 CFR 701.26 from policies, procedures, and training materials once the rule is effective.
• Firms should consider confirming that contract templates still include written terms addressing audit rights, information security, business continuity, indemnification, performance metrics, data ownership and return, termination, and dispute resolution.
• Credit unions involved in shared operational arrangements may wish to review whether documentation now reflects the updated clarification in 12 CFR 721.3.
• Firms may wish to confirm that third-party risk management, vendor oversight, and due diligence controls remain aligned with existing supervisory expectations despite the regulatory deletion.

What changed

The final rule rescinds 12 CFR 701.26, which had addressed FCU authority to enter written contracts for assets or services relating to daily operations and required those agreements to be in writing. NCUA states that the contractual authority already exists under the FCU Act and incidental powers authority, so the regulation was redundant. The Board also amended 12 CFR 721.3 to formally clarify that credit unions may act as representatives in shared operational arrangements with other credit unions or organizations, and that fixed assets may be shared.

Key dates

2011-07-22

CFTC adopted Part 20 as a temporary large trader reporting framework for physical commodity swaps.

2026-07-21

Final order effective date; routine Part 20 reporting requirements become ineffective and unenforceable.

Suggested considerations

• Compliance teams may wish to confirm that Part 20 daily and event-based filing workflows are disabled or archived as of the effective date.
• Firms may wish to retain the underlying books, records, and futures-equivalent conversion methodologies required for special-call production under § 20.6 and related retained provisions.
• Operational teams may wish to map any legacy Part 20 controls to SDR, Parts 43 and 45, and Part 150 processes to avoid duplicate reporting.
• Firms may wish to review document retention and response procedures so that special-call requests can be answered promptly if the CFTC seeks underlying records.
• Compliance functions may wish to update internal regulatory inventories and policies to reflect that Part 20 routine reporting is no longer enforceable, while recordkeeping obligations remain.

What changed

The order renders the routine position-reporting requirements of Part 20 ineffective and unenforceable, so clearing organizations, clearing members, and swap dealers are no longer required to file the daily and event-based reports previously required under §§ 20.3, 20.4, 20.5, and related reporting provisions. The CFTC is retaining, under § 20.9(b), the recordkeeping and special-call provisions, including the obligation to keep records of paired swaps and swaptions and the methods used to convert positions into futures equivalents and to produce those records on request.

Key dates

2025-07-25

CME requested exemptive relief from CFTC regulation 41.25(c)

2026-07-10

SEC granted CME exemptive relief, subject to heightened listing standards

2026-07-15

CME submitted an updated request to the CFTC incorporating the SEC-conditioned listing standards

2026-07-16

CFTC order became applicable

2026-07-21

Federal Register publication date of the CFTC order

Suggested considerations

• Compliance teams may wish to review whether any proposed or existing single-stock futures products rely on opening-price settlement and whether the CME order changes product design assumptions.
• Firms may wish to confirm that the relevant underlying securities satisfy CME’s heightened liquidity and market-capitalization listing standards before marketing, clearing, or supporting these contracts.
• Market surveillance teams may wish to assess whether surveillance procedures need updating for closing-price settlement mechanics and end-of-day manipulation risks.
• Operational teams may wish to align settlement, market data, and surveillance processes with the product’s closing-price final settlement methodology.
• Legal and regulatory teams may wish to track the separate SEC and CFTC conditions, since CME’s ability to proceed depends on both regimes.

What changed

The order exempts CME from CFTC regulation 41.25(c), which generally requires the final settlement price of a cash-settled security futures product to fairly reflect the opening price of the underlying security or securities. The relief is granted under regulation 41.25(e), which permits exemptions on specified terms and conditions when consistent with the public interest and the protection of customers.

Key dates

2026-07-17

Federal Register publication date for the final rule

2026-08-17 Deadline

Final rule effective date

Suggested considerations

• Compliance teams may wish to identify whether any counterparties qualify as eligible seeded funds under the revised margin-affiliate definition and document the three-year trading-inception window.
• Firms may wish to refresh margin threshold calculations to reflect the exclusion of qualifying seeded funds from margin-affiliate aggregation.
• Operational teams may wish to update collateral eligibility schedules so that money market and similar fund securities are assessed under the expanded eligible-collateral framework.
• Risk and valuation teams may wish to confirm haircut logic under Commission Regulation 23.156(a)(3) for money market and similar funds.
• Legal and compliance functions may wish to map the final rule against existing IM procedures, counterparty onboarding language, and margin agreements to determine whether amendments are needed before the effective date.
• Firms may wish to coordinate with fund sponsors and asset managers to verify the fund's start-up capital structure, independence, support limitations, and commencement of trading for any seeded-fund analysis.

What changed

['The Commission revised the definition of "margin affiliate" so that certain collective investment vehicles that receive start-up capital from a sponsor entity, referred to as "seeded funds," are treated as having no margin affiliates or as not constituting margin affiliates of another entity for purposes of the initial margin threshold calculation.', "For eligible seeded funds, swap dealers and major swap participants subject to the CFTC uncleared swaps margin rules are relieved from the requirement to post and collect initial margin for up to three years from the fund's trading inception...

Key dates

TBD (2026)

– SEC press release date and effective date of the joint data standards rule (exact calendar date to be taken from the final rule and press release)

TBD (2026–2027)

– SEC and other participating agencies publish technical specifications, schemas, and implementation guides for specific forms and data collections that will transition to the joint data standards

TBD (2027 and beyond) Deadline

– Phased compliance dates for particular reporting forms and regimes as each agency completes its implementation plans under the FDTA; individual forms will have distinct first‑applicable reporting periods and transition windows

Suggested considerations

• Conduct a comprehensive mapping of all current and upcoming regulatory data submissions to the SEC and other FDTA‑covered agencies to identify which reports are likely to be brought under the joint data standards.
• Review and update data governance frameworks so that key data elements (counterparty identifiers, instrument identifiers, balances, exposures, classifications) are uniquely defined, consistently sourced, and traceable across internal systems in alignment with anticipated joint taxonomies.
• Assess existing regulatory reporting systems and vendor solutions (including XBRL tools, data warehouses, and filing platforms) and develop an upgrade plan to support the new machine‑readable, standardized formats and schemas.
• Establish an internal FDTA/joint data standards implementation program, with clear ownership (e.g., finance, regulatory reporting, data management, IT) and a cross‑functional steering committee to oversee design, testing, and rollout.
• Engage with technology, regtech, and data vendors to confirm their timelines for supporting the new SEC and cross‑agency standards and to obtain updated taxonomies, schemas, and validation rules as soon as they are published.

What changed

• - The SEC, jointly with seven other U.S. financial regulators, has established mandatory technical data standards for information submitted to those agencies pursuant to the Financial Data...
• The joint standards apply to regulatory data collections within each participating agency’s remit (e.g., SEC filings and reports, certain prudential and market data submissions), and are intended to...
• The rule requires use of structured, non‑proprietary, machine‑readable formats (such as XML, JSON, XBRL, or similar open standards) where data is collected electronically, moving away from...
• The standards require use of public, non‑exclusive data dictionaries and taxonomies, so that data elements (e.g., fields, metrics, identifiers) are consistently defined and tagged across different...
• The rule embeds interoperability requirements, so that the same data element (for example, a LEI, CUSIP, counterparty ID, asset class, or exposure type) is reported using harmonized definitions and...