Mortgage & Lending

Key dates

2026-04-22

The CFPB published a final rule amending Regulation B provisions concerning special purpose credit programs, including new restrictions applicable to programs offered or participated in by for-profit organizations.

2026-07-21

The CFPB's Regulation B amendments became effective. For-profit special purpose credit programs offered or participated in on or after this date must comply with the amended requirements, including the prohibition on using race, color, national origin, or sex as a common eligibility criterion.

2026-08-25

The seven agencies rescinded the 2022 interagency statement and OCC Bulletin 2022-3, effective immediately. Creditors should no longer rely on those issuances or related guidance.

Suggested considerations

• Compliance teams may wish to inventory special purpose credit programs, marketing, eligibility criteria, underwriting policies, written plans, and monitoring practices that were developed or supported by the 2022 interagency statement, OCC Bulletin 2022-3, or related guidance.
• Firms should consider reassessing any program that uses race, color, national origin, or sex as a common eligibility criterion, particularly for credit extended on or after July 21, 2026, against 12 CFR 1002.8 as amended.
• For-profit creditors may wish to confirm that each written special purpose credit program plan contains evidence of need, explains why the relevant class would not receive credit under the organization's ordinary creditworthiness standards, and supports any eligibility characteristic used by the program.
• Compliance teams may wish to remove rescinded guidance from policies, procedures, training materials, legal inventories, product governance documents, and examiner-facing materials, while retaining records needed to explain prior program design and implementation.
• Firms should consider reviewing program communications and applicant data practices for potential discrimination or misleading reliance on the rescinded statement, including communications suggesting that protected-class distinctions are broadly authorized.
• Banks and credit unions may wish to brief fair-lending, legal, product, underwriting, marketing, and model-risk stakeholders and document the governance decision regarding whether each program should be amended, suspended, or continued under current law.

What changed

The 2022 interagency statement and OCC Bulletin 2022-3 are rescinded, effective immediately, and creditors are instructed not to rely on those issuances or related guidance. The rescission does not eliminate the statutory or regulatory framework for special purpose credit programs under ECOA and Regulation B, including 12 CFR 1002.8; rather, it clarifies that those programs remain subject to applicable fair-lending prohibitions. The agencies specifically identify the prior version of Regulation B referenced by the 2022 statement as having been amended.

Key dates

2020-11-13

The High Court disqualified Howard Roland Duckett from acting as a company director for 10 years under section 6 of the Company Directors Disqualification Act 1986.

2020-12-04

The 10-year company-director disqualification took effect and is stated to run until 2030-12-04.

2025-11-20

The FCA identified this date in consumer communications as the point after which payments requested by Beauforce should be reported; the firm was restricted from regulated activities and ordered to stop accepting consumer money.

2026-08-18

The FCA announced the prohibition of Howard Roland Duckett from performing functions in relation to regulated activities.

Suggested considerations

• Compliance teams may wish to review fitness-and-propriety checks for current and prospective senior managers, including searches for director disqualifications, litigation findings, insolvency events, and other adverse information.
• Firms should consider confirming that senior managers have disclosed all matters relevant to their approval and that changes affecting their fitness, propriety, or ability to perform an SMF are escalated and notified to the FCA where required.
• Firms should consider testing compliance with FCA Principle 11, COCON 2.2.4R, and SUP 10C.14.18R in relation to open, cooperative, and timely dealings with the FCA and notification of disqualifications or other relevant changes.
• Boards and compliance functions may wish to assess whether regulatory records, management-accountability maps, company-director registers, and evidence supporting senior-manager attestations are complete, consistent, and independently verifiable.
• Consumer-credit firms should consider reviewing controls over debt-management client payments, client-money safeguarding, communications, and contingency arrangements for transferring customers if permissions are restricted or withdrawn.
• Firms should consider screening current staff and approved persons against the FCA Financial Services Register and relevant Companies House director-disqualification information before appointment and periodically thereafter.
• Compliance teams may wish to use the case in senior-manager and conduct-risk training to reinforce that misleading the FCA or relying on fabricated information can independently support prohibition, even where the underlying misconduct occurred at an unrelated company.

What changed

The FCA made an individual prohibition order under section 56 of the Financial Services and Markets Act 2000 and withdrew Duckett’s approval to perform the SMF3 Executive Director and SMF16 Compliance Oversight functions under section 63 of that Act. This is an enforcement outcome against a specific individual rather than a new generally applicable rule. The underlying conduct included inadequate company records, repeated lies and reliance on fabricated evidence in High Court proceedings, and failure to notify the FCA of a director disqualification.

Key dates

20 March 2026

- The FCA published the statement announcing increased scrutiny of Annex 1 firms and warning that registration applications should be expected to take longer

TBD (ongoing, from the date of publication)

- Annex 1 firms that are not registered should submit a registration application before continuing Annex 1 activity, because the FCA states such firms need to be registered for AML purposes

TBD (ongoing supervisory cycle)

- Around 900 Annex 1 firms are subject to FCA information requests to support supervisory risk assessment and intelligence gathering

Suggested considerations

• Confirm whether any UK business line falls within Annex 1 scope and, if so, verify that the entity is registered with the FCA for AML purposes before continuing the activity.
• Submit a registration application immediately if the firm carries on Annex 1 activity without being registered.
• Reassess the firm’s AML framework at entity level, rather than relying on group-level policies or parent-company controls, and document why the controls are appropriate for the firm’s own risks and operations.
• Replace any generic or off-the-shelf procedures with policies, controls, and procedures tailored to the firm’s actual products, customers, geographies, and delivery model.
• Prepare evidence of MLR compliance for FCA review, including risk assessment logic, governance arrangements, customer due diligence processes, and monitoring controls.

What changed

• - The FCA is closely scrutinising applications to register as an Annex 1 firm, indicating a tougher gateway for new registrations and potentially more refusals or delay where evidence is weak.
• Annex 1 firms must demonstrate compliance with the Money Laundering Regulations, rather than merely assert that controls exist.
• The FCA is warning firms that registration applications will take longer, which affects launch plans, transaction timing, and group structuring decisions.
• The FCA has sent an information request to around 900 Annex 1 firms to better understand their activities, business models, and risks.
• The FCA says it will use this information, together with other intelligence, to identify and disrupt financial crime risks in the sector.

Key dates

2026-08-04

Publication of the Federal Reserve Board notice of proposed rulemaking ‘Regulatory Modernization and Relief for Mutual Holding Companies’ in the Federal Register (91 FR 49490; FR Doc. 2026-15774) amending Regulations Q (12 CFR part 217) and MM (12 CFR part 239).

2026-10-05 Deadline

Comment deadline for submitting responses to the Federal Reserve Board on the proposed amendments to Regulations Q and MM (Docket No. R-1895; RIN 7100-AH26).

Suggested considerations

• Compliance teams at mutual holding companies and savings and loan holding companies may wish to review the proposed amendments to Regulation MM (12 CFR part 239), particularly the sections on dividend waivers, mutual-to-stock conversion processes, post-conversion restrictions, chartering requirements for subsidiary holding companies, and updated model charters and bylaws, to assess operational and governance impacts.
• Firms planning or contemplating mutual-to-stock conversions should consider comparing their current conversion documentation, use of FR MM-PS, FR MM-OC and FR MM-OF forms, and liquidation account methodologies with the proposed streamlined forms, corrected liquidation account calculations, and revised rules on stock pricing, repurchases, offers and sales, employee stock ownership plan financing and benefit plans.
• Institutions that issue, or are considering issuing, mutual capital certificates should review the proposed Appendices B and C to Regulation Q (12 CFR part 217) to evaluate whether their existing or planned instrument terms align with the model key terms for qualification as Common Equity Tier 1 or Additional Tier 1 capital, including permanence, loss-absorption, distributions and redemption features.
• Subsidiary holding companies of thrift mutual holding companies may wish to analyze the proposed elimination of the federal charter requirement and related changes to Subpart C of Regulation MM to determine chartering options, corporate structure implications, and any needed updates to organizational documents and regulatory commitments.
• Governance and legal teams at MHCs could review the proposed revisions to membership rights, proxy processes, postal mail requirements, voluntary dissolution, and the model charter and bylaws in Appendices A, C and D to Regulation MM, with a view to aligning internal policies and corporate governance frameworks with the modernized regime once finalized.
• Risk and capital management functions at bank holding companies, savings and loan holding companies and state member banks should consider evaluating capital planning assumptions and buffers in light of the clarified eligibility of mutual capital instruments as regulatory capital under Regulation Q, and identify any systems or reporting changes that may be required if the proposal is adopted.
• All affected firms may wish to prepare internal impact assessments and, where appropriate, draft comment letters addressing specific elements of Regulations Q and MM (Docket No. R-1895; RIN 7100-AH26), including any perceived risks around conflicts of interest, reduced accountability, or adjustment costs noted in the economic analysis.
• Compliance monitoring teams should plan to track the rulemaking through the comment close date and subsequent Federal Reserve actions so that, if the proposal is finalized, implementation plans can be developed for policy updates, staff training and revisions to regulatory reporting and capital instrument documentation.

What changed

The NPR proposes targeted amendments to Regulation MM (12 CFR part 239) governing mutual holding companies (MHCs), including eliminating certain dividend waiver requirements that currently apply to MHCs and their subsidiary holding companies, and revising post-conversion restrictions to reduce burdens following mutual-to-stock conversions.

Key dates

23 August 2018

– Initial version of CMI 27/2018 “Controls and Disclosures to be Implemented by Licensed Securities-Based Crowdfunding Operators” published by MAS

08 October 2018

– MAS publishes FAQs on Lending-based Crowdfunding, clarifying licensing and prospectus requirements and interacting with SCF-related guidance

05 March 2021

– Updated version of CMI 27/2018 and Annex A / A1 / A2 for issuer default notification uploaded, refining default reporting and controls expected of SCF operators

21 January 2025

– Revision of Guidelines on Criteria for the Grant of a Capital Markets Services Licence (SFA 04-G01), which interact with licensing expectations for SCF operators

14 July 2026

– Last revised date of circular CMI 27/2018, signalling the most recent MAS expectations on controls and disclosures for licensed SCF operators

Suggested considerations

• Review existing issuer due diligence policies and procedures and update them to align with MAS’s expectations on structured checks, documentation, and investor disclosure of due diligence scope for all SCF offers.
• Implement a formal policy prohibiting the use of new loans to repay existing overdue loans, except where legitimate reasons exist; define those reasons, approval thresholds and documentation requirements for exceptions.
• Enhance lending workflows to ensure that, when new loans are extended to borrowers with outstanding loans, the platform system automatically collates and presents total outstanding exposure and the rationale for the new loan to investors in pre-investment disclosures.
• Develop and approve a detailed issuer default management framework that defines escalation triggers, recovery options, decision criteria, investor communication templates, and record-keeping requirements.
• Update investor terms and conditions and consent mechanisms so that investors explicitly agree to any potential recovery-related costs, with clear fee schedules and scenarios disclosed before costs are incurred.

What changed

• - Licensed SCF operators must implement structured due diligence checks on issuers, including clear policies on information to be obtained, risk assessment criteria and documentation standards, and...
• Lending-based SCF operators are generally prohibited from allowing a borrower to take up a new loan to repay an existing overdue loan, unless there are legitimate, documented reasons to extend a new...
• Where a lending-based SCF operator does extend a new loan to a borrower with outstanding loans, it must disclose the borrower’s total outstanding loans and the reasons for extending the new loan so...
• SCF operators must establish formal policies and procedures for issuer default management, documenting circumstances under which the operator will pursue various recovery options (e.g.
• Operators must disclose to investors the different recovery options and associated costs and must seek and obtain investors’ consent before incurring any recovery-related costs that will be borne by...

Key dates

2026-06-08

CFPB issued the Statement on Ability To Repay and Immigration Status referenced by the agencies

2026-07-13

FDIC, OCC, and NCUA issued the interagency guidance on lending to individuals not legally authorized to work in the United States

Suggested considerations

• Compliance teams may wish to review underwriting standards to confirm that capacity-to-repay analysis captures employment-authorization-related income instability.
• Firms should consider whether credit policy, risk grading, and portfolio monitoring procedures explicitly address elevated repayment uncertainty for non-work-authorized borrowers.
• Institutions may wish to reassess documentation and verification controls for income, employment, and supporting records in light of the agencies' stated focus on safe-and-sound lending.
• Teams should consider whether fair-lending, TILA, and ECOA controls are aligned with the CFPB's June 8, 2026 statement and the interagency guidance.
• Risk and finance functions may wish to evaluate whether allowance, concentration risk, and credit-loss assumptions need updating where exposure to this borrower segment is material.

What changed

The publication does not create a new lending ban or a new standalone rule. Instead, it restates that institutions should identify, measure, monitor, and control the credit risks associated with borrowers who are not legally authorized to work in the United States through underwriting practices that assess willingness and capacity to repay according to the credit terms. The guidance specifically links this issue to the CFPB's June 8, 2026 Statement on Ability To Repay and Immigration Status and reminds creditors of obligations under the Truth in Lending Act as implemented by Regulation Z,...

Key dates

2026-07-13

OCC, FDIC, and NCUA issued the interagency guidance

2026-06-08

CFPB issued its Statement on Ability To Repay and Immigration Status, referenced by the guidance

Suggested considerations

• Compliance teams may wish to review underwriting standards to confirm that repayment capacity, source of repayment, and overall financial condition are assessed consistently for borrowers whose work authorization is uncertain.
• Firms may wish to test whether account management, credit classification, and allowance methodologies adequately capture elevated credit risk linked to employment authorization uncertainty.
• Institutions may wish to review consumer compliance controls for alignment with TILA, Regulation Z, ECOA, and Regulation B when evaluating applicants affected by immigration or work-authorized status.
• Risk and compliance teams may wish to update portfolio monitoring, concentration analysis, and documentation standards so that the identified credit risk factors are reflected in governance and reporting.
• Community banks may wish to verify that loan policy language and examiner-facing documentation clearly show how these risks are being identified, measured, monitored, and controlled.

What changed

The publication is guidance, not a new rule or statute, and it reinforces existing expectations rather than imposing a new legal prohibition. It states that lending to individuals not legally authorized to work in the United States may present elevated credit risk because their ability to generate income, maintain employment, and remain financially stable may be more uncertain.

Key dates

18 November 2025

– Consultation on the proposed motor finance redress scheme closes (CP25/27), feeding into the final PS26/3 rules

5 December 2025 Deadline

– Firms must start sending final responses to any motor leasing complaint in line with normal complaint‑handling rules (outside the scheme‑specific pause)

1 May 2026

– FCA confirms its motor finance compensation scheme has been legally challenged, triggering the Upper Tribunal process

31 May 2026

– FCA lifts the general pause on handling certain motor finance complaints, returning many complaints to standard DISP timeframes, alongside the emerging scheme

30 June 2026

– Original end of the implementation period for loans taken out from 1 April 2014 under PS26/3 (now effectively paused for redress calculation/payment/communications)

Suggested considerations

• Identify and maintain a complete inventory of motor finance complaints and agreements that fall within the scheme scope (regulated motor finance with relevant commission arrangements between April 2007 and 2024).
• Continue to gather, centralise and validate data on commission structures, commission levels, and disclosure practices for all in‑scope agreements, including by issuing targeted information requests to brokers and dealers.
• Implement internal workflows to ensure brokers respond to lenders’ information requests within one month, or formally confirm where requested documents or data are not held.
• Review and classify complaints to determine which consumers are not owed compensation under the scheme, including cases outside scope and those lacking discretionary, high or tied commission arrangements, and prepare appropriate communications.
• Assess complaints for time‑bar issues and apply the scheme’s limitation and out‑of‑time principles consistently, documenting rationale for any reliance on time‑bar to decline redress.

What changed

• - Parts of the FCA motor finance consumer redress scheme under PS26/3 are formally suspended by order of the Upper Tribunal, on terms agreed between the FCA and four challengers (Consumer...
• During the suspension, firms are not required to calculate redress, pay compensation, or send communications about compensation owed under the scheme according to the original timetable.
• All non‑suspended rules remain fully applicable, including duties to identify in‑scope complaints and agreements, gather commission and disclosure data (including from brokers), and maintain records.
• Lenders must continue to identify relevant complaints and agreements falling within scheme scope (motor finance agreements between 2007 and 2024 with potentially unfair commission arrangements).
• Firms must continue to gather data on commission arrangements and disclosure practices, including obtaining information from brokers and confirming where such information is not held.

Key dates

15 October 2013

- Council Regulation (EU) No 1024/2013 enters into force, granting the ECB sanctioning powers for prudential supervision of credit institutions (contextual basis for this enforcement)

Q4 2023

- Start of the period during which BIL failed to apply its approved internal models to expected loss calculation for defaulted retail and corporate exposures, leading to overstated capital

Q1 2024

- Second consecutive quarter in which incorrect expected loss and IRB shortfall calculations continued to affect reported capital and capital ratios

Q2 2024

- Third consecutive quarter of miscalculation; end of the period identified by the ECB as affected by the breach

29 June 2026

- The ECB publishes its decision imposing an administrative penalty of €3.255 million on BIL for the severe breach of its decision on internal models

Suggested considerations

• Review and confirm that all regulatory capital calculations, including expected loss and IRB shortfall for defaulted exposures, consistently use the approved internal models as authorised by the ECB or national competent authority.
• Map and reconcile the internal-model implementation across risk systems, finance, and regulatory reporting to ensure that there are no manual overrides, alternative methods, or parallel calculations that deviate from the approved model specifications.
• Strengthen model risk governance by ensuring that any proposed changes to expected loss methodologies, including for defaulted retail and corporate portfolios, are formally approved by the competent authority before being used in regulatory capital reporting.
• Implement robust controls and periodic testing within Finance, Risk, and Regulatory Reporting functions to detect and prevent misapplication or non-application of approved internal models, with clear escalation procedures for identified discrepancies.
• Ensure that the calculation of IRB shortfall (difference between expected loss and accounting provisions) is independently validated and appropriately deducted from CET1 capital in accordance with CRR and ECB internal models guidance.

What changed

• - The ECB has reaffirmed that institutions using internal ratings-based (IRB) approaches must apply their approved internal models consistently for expected loss calculation on defaulted retail and...
• The ECB has underscored that the IRB shortfall (difference between expected loss and accounting provisions) must be correctly calculated and deducted from regulatory capital whenever expected loss...
• The ECB has classified intentional failure to apply approved internal models to expected loss calculations as a “severe” breach under its Guide to the method of setting administrative pecuniary...
• The enforcement action confirms the ECB’s readiness to use its sanctioning powers under Article 18 of Council Regulation (EU) No 1024/2013 against internal-model users that misreport capital due to...
• The case highlights that miscalculation of expected loss and IRB shortfall over multiple reporting periods, even without an explicit capital ratio breach of minima, can be sanctioned where capital...

Key dates

26 June 2026

- CBI publishes the warning notice against Loan Empower Solution as an unauthorised retail credit firm and lists the firm under section 53 of the Central Bank (Supervision and Enforcement) Act 2013

Suggested considerations

• Review and update internal unauthorised-firm and scam monitoring procedures to ensure Loan Empower Solution and its identifiers (name, website, address, email, telephone number) are captured in watchlists, fraud rules, and staff guidance.
• Screen recent and ongoing customer transactions and communications for any references to Loan Empower Solution or similar lending scams requesting upfront “loan fees”, and escalate any matches to fraud and compliance teams.
• Update customer-facing communications and website scam warnings to highlight the risk of advance fee fraud in retail credit, referencing the need to check the CBI registers and unauthorised-firms list before engaging with lenders.
• Ensure call centre, branch, and digital support staff are trained to identify and respond to customers approached by unauthorised lenders, including how to advise customers to verify authorisation status on the CBI website and to report suspected scams.
• Incorporate checks against the CBI unauthorised firms search into onboarding, due diligence, and third-party risk management processes for any lending-related partnerships, introducers, or lead generators.

What changed

• - The CBI has added Loan Empower Solution (website: lesolution.eu) to its public list of unauthorised firms and explicitly categorised it as an unauthorised retail credit firm operating without the...
• The CBI has publicly stated that Loan Empower Solution appears to be operating an advance fee fraud model, where upfront payments are requested for credit services that are never provided.
• The CBI has confirmed that the firm is using a purported Irish business address (The Merrion Buildings, 18–20 Merrion Street, Dublin 2, D02 XH98), a non-Irish telephone number, and a specified...
• The firm’s name has been published under section 53 of the Central Bank (Supervision and Enforcement) Act 2013, reaffirming the CBI’s use of its statutory power to publicly identify entities...
• The CBI has directed the public to its unauthorised firms search and financial scams information pages, implicitly reinforcing expectations that firms promote use of these tools in their consumer...

Key dates

21 May 2026

- OSFI launches a 60‑day public consultation on targeted amendments to Guideline B‑12 – Interest Rate Risk Management and related IRRBB Pillar 3 disclosure expectations

20 July 2026 Deadline

- Deadline for stakeholders to submit comments on the draft Guideline B‑12 amendments and associated IRRBB disclosure proposals to [email protected]

10 September 2026

- OSFI plans to publish the final revised Guideline B‑12, together with a non‑attributed summary of comments received and OSFI’s responses

01 November 2026

- Revised Guideline B‑12 becomes effective for institutions with a fiscal year ending 31 October

01 January 2027

- Revised Guideline B‑12 becomes effective for institutions with a fiscal year ending 31 December

Suggested considerations

• Perform a gap analysis comparing current interest rate risk in the banking book methodologies, shock scenarios, and assumptions against the proposed revised Guideline B‑12 parameters and BCBS‑aligned calibration approach.
• Engage internal stakeholders (risk management, treasury/ALM, finance, regulatory reporting, model validation, and internal audit) to review the consultation text and identify operational, data, and model impacts from the extended December 2015–December 2023 calibration window and new shock design.
• Prepare and submit a detailed written response to OSFI at [email protected] by 20 July 2026, highlighting any concerns with scenario calibration, procyclicality, data availability, systems impacts, and implementation timelines.
• Update IRRBB models, interest rate scenario engines, behavioral assumptions (e.g., non‑maturity deposits, prepayments), and risk metrics (e.g., economic value of equity and earnings‑at‑risk) to incorporate the revised OSFI shock scenarios once the final guideline is published on 10 September 2026.
• Revise internal IRRBB policies, risk appetite statements, limits frameworks, and governance documentation to align with the updated Guideline B‑12 expectations and ensure Board and senior management oversight reflects the new calibration.

What changed

• - OSFI proposes to amend Guideline B‑12 – Interest Rate Risk Management to update prescribed interest rate shock scenarios used for measuring interest rate risk in the banking book.
• The interest rate shock calibration will be aligned with the most recent BCBS methodology for IRRBB, including improved treatment of environments where policy rates are close to zero or negative.
• The time series used to calibrate interest rate shock scenarios will be extended from a previous cut‑off of December 2015 to now incorporate data through December 2023, capturing the recent period of...
• OSFI intends to strengthen transparency and market discipline by consulting simultaneously on proposed amendments to Pillar 3 disclosure expectations related to interest rate risk in the banking book.
• The revised B‑12 guideline will introduce updated expectations for IRR measurement, monitoring, and reporting that ensure institutions recognize more recent market experience in their internal risk...

Key dates

14 April 2026

Publication date of warning notice; Immediate public alert on unauthorised status of Finance Advice Help.[Source URL: https://www.centralbank.ie/news/article/finance-advice-help--central-bank-of-ireland-issues-warning-on-unauthorised-firm]

Suggested considerations

• Verify firm status: Use CBI's unauthorised firms search tool before engaging with any retail credit provider (https://www.centralbank.ie/regulation/how-we-regulate/authorisation/unauthorised-firms/search-unauthorised-firms).
• Report suspicions: Contact CBI at (01) 224 5800 or via direct reporting portal for any dealings with Finance Advice Help or similar entities.[Source URL: https://www.centralbank.ie/news/article/finance-advice-help--central-bank-of-ireland-issues-warning-on-unauthorised-firm]
• Educate clients/staff: Disseminate scam protection guidance from www.centralbank.ie/financialscams; implement "SAFE test" for verification.[Source URL: https://www.centralbank.ie/news/article/finance-advice-help--central-bank-of-ireland-issues-warning-on-unauthorised-firm]
• Monitor clones: Screen for impersonation risks, as seen in related warnings (e.g., Shamrock Lend clone).

What changed

This is not a regulatory change but an enforcement action via a public warning notice. It reinforces existing requirements under the Central Bank (Supervision and Enforcement) Act 2013 (section 53), which empowers CBI to publish names of unauthorised firms offering regulated services like retail credit. No new rules are introduced; it signals ongoing vigilance against unauthorised retail credit providers.[Source URL: https://www.centralbank.ie/news/article/finance-advice-help--central-bank-of-ireland-issues-warning-on-unauthorised-firm]

Key dates

08 April 2026

Announcement and effective date; CBI press release details the amendment, with immediate application implied for qualifying bridging loans (no explicit phase-in mentioned)

Suggested considerations

• Update lending policies: Identify and classify principal home bridging loans (max 18 months, repayment from property sale, no capital repayments required during term) to apply LTI exemption but enforce 90% LTV.
• Enhance underwriting: Conduct individual suitability and affordability assessments beyond macroprudential limits; do not rely solely on exemption.
• Strengthen consumer protections: Fully inform borrowers of risks (e.g., sale delays, interest costs); ensure products suit circumstances per consumer protection rules.
• Internal monitoring and reporting: Track bridging loan volumes within flexibility allowances; prepare for CBI inquiries as part of ongoing assessments.
• Staff training and systems updates: Revise origination, disclosure, and compliance systems promptly to operationalize changes.

What changed

• - Exemption from LTI limit: Principal home bridging loans—defined as short-term loans (maximum 18 months) enabling homeowners to buy a new principal home before selling their current property, repaid...
• LTV limit retained: Maximum 90% LTV continues to apply to these loans, alongside the 15% flexibility allowance for first-time/second/subsequent buyer lending.
• No other changes: All remaining mortgage measures, including consumer protection rules and lenders' prudent underwriting obligations, stay intact.
• Monitoring commitment: CBI will track the exemption's operation within its regular mortgage measures assessments for unintended risks.

Key dates

1 February 2021

12 December 2023; Period of Buckley's admitted misconduct (diverting payments and misrepresenting qualifications)

25 February 2026

Effective date of the indefinite prohibition on Buckley performing any controlled functions

01 April 2026

Publication date of the CBI press release announcing the Prohibition Notice

Suggested considerations

• Firms employing similar roles: Immediately review invoicing processes to ensure payments direct only to firm accounts, with segregation of duties and dual approvals for client billing.
• Fitness and Probity assessments: Conduct enhanced due diligence on customer-facing staff, verifying qualifications via independent sources and monitoring for personal financial gain conflicts.
• Incident reporting: Escalate any suspected integrity breaches (e.g., qualification misrepresentation or fund diversion) to CBI under fitness and probity notification obligations.
• Training programs: Update mandatory training on Fitness and Probity Standards (available at https://www.centralbank.ie/regulation/fitness-and-probity), focusing on honesty in client interactions.
• Prohibition checks: Screen all controlled function holders against CBI's public prohibitions list before approvals or role changes.

What changed

This is not a new regulation but an enforcement outcome under the existing Fitness and Probity Regime, established by the Central Bank Reform Act 2010, which mandates high standards of competence, integrity, and honesty for individuals in controlled functions. No regulatory changes are introduced; instead, it reinforces enforcement mechanisms, including investigations and prohibitions for breaches, particularly in customer-facing roles where honesty is paramount.

Key dates

9 July 2025 Deadline

PRA offers interim modification by consent applications; firms must submit business plan/risk info within 1 month, then monthly reports (first covering prior 3 months)

11 July 2025

£150M threshold increase effective

TBD 2026 Deadline

PRA consultation on permanent LTI flow limit changes (due course post-review)

30 June 2026

Interim modifications expire (or earlier if rules amended)

Suggested considerations

• Apply for modification (if seeking >15% high-LTI): Submit detailed business plan (incl. quarterly high-LTI projections), risk appetite, management frameworks; provide monthly notifications on approvals/completions.
• Monitor thresholds: Track rolling 4-quarter mortgage volumes/contracts (≥£150M and ≥300 contracts in two periods triggers limit).
• Record-keeping: Document high-LTI allowances, group allocations, exclusions.
• Respond to consultation: Provide feedback on CP6/26 proposals via PRA channels (deadline not specified in summary; check full paper).
• Engage regulators: FCA firms contact FCA for tailored guidance on high-LTI increases.

What changed

• - Review of LTI flow limit: PRA is reviewing the rule limiting new residential mortgages with LTI ≥4.5x to 15% of total new lending, following FPC recommendations; no final changes proposed yet, but...
• Threshold increase (prior update): Flow limit now triggers only for firms issuing ≥£150M in residential mortgages annually (up from £100M), effective 11 July 2025, exempting ~80 smaller lenders (up...
• Interim modification by consent: Firms can apply to disapply the 15% cap temporarily; requires submitting business plans, risk frameworks, and monthly reporting on high-LTI volumes.
• Exclusions remain: No LTI limit for re-mortgages (no principal change), lifetime mortgages, or second/subsequent charge mortgages (per historical rules).
• Group allocations: Firms in groups can share high-LTI allowances, with record-keeping required.

Key dates

6 April 2007

1 November 2024; Scope of agreements eligible for compensation

26 March 2020 Deadline

Cut-off for excluding high commission cases if clearly disclosed (firms must explain and allow FOS challenge)

2026 (this year)

Millions compensated

30 June 2026

End of implementation for 1 April 2014+ loans; lenders then have 3 months to notify complainants of redress

31 August 2026

End of implementation for 6 April 2007-31 March 2014 loans; lenders then have 3 months to notify complainants and 6 months for eligible non-complainants

Suggested considerations

• Identify all in-scope agreements (2007-2024 with broker commissions); assess eligibility against tightened criteria (e.g., undisclosed DCA/high commission/tie).
• Contact complainants within 3 months post-implementation; eligible non-complainants within 6 months; invite scheme participation (6-month consumer response window).
• Calculate redress per formula (commission-based, capped, with interest); pay promptly, allowing set-off against customer debts where applicable.
• Gather records now (FCA expectation pre-rules); handle exclusions/exceptions with explanations; prepare for FOS challenges on time-bars.
• Brokers: Respond to lender information requests.

What changed

• - Tightened eligibility: Excludes minimal commission agreements (£120 or less pre-1 April 2014; £150 or less post), zero APRs, unused DCAs, and contractual ties where lenders prove visible...
• Two schemes: Separate for 6 April 2007-31 March 2014 and 1 April 2014-1 November 2024 to mitigate legal challenges on pre-2014 powers.
• Compensation adjustments: Reflects higher 2007-2014 losses; capped in ~1/3 cases to avoid over-compensation.
• Streamlined operations: Lenders contact only complainants or eligible non-complainants; no recorded delivery required, cutting delivery costs >40%.
• Scope expansion: Covers DCAs, high commissions, and contractual ties under Consumer Credit Act 1974 ss.140A-C; includes deceased consumers.

Key dates

17 December 2018

- Original issuance of Circular CSSF 18/703 introducing semi-annual reporting

25 March 2026

- Publication date of Circular CSSF 26/908 (today)

Suggested considerations

• Download and review the full Circular CSSF 26/908 (291.96Kb PDF) and the updated consolidated Circular CSSF 18/703 (258.91Kb PDF) from the CSSF website: https://www.cssf.lu/en/Document/circular-cssf-26-908/.
• Conduct a gap analysis of current reporting processes against the amended requirements for borrower-related residential real estate indicators.
• Update internal systems, data collection templates, and reporting workflows to ensure accurate semi-annual submissions to the CSSF.
• Train relevant compliance, risk, and finance teams on changes; document compliance confirmations for audit trails.

What changed

The circular introduces amendments to the original Circular CSSF 18/703 (itself amended by Circulars CSSF 20/737 and 21/772), focusing on semi-annual reporting of indicators tied to borrowers in residential real estate. Specific changes are not detailed in the provided summary or full content excerpt, but they likely involve refinements to reporting templates, data granularity, or submission processes to align with evolving EU prudential standards on real estate risk monitoring. The updated consolidated version of Circular CSSF 18/703 is now available as a 258.91Kb PDF.

Key dates

December 3, 2020

- CSSF Regulation No 20-08 originally published

January 1, 2021

- Regulation and LTV limits became effective for residential real estate credit on Luxembourg territory

May 21, 2024

- CSSF Regulation No 24-04 introduced temporary adjustments to LTV limits

December 30, 2024

- CSSF Regulation No 24-10 extended temporary adjustments

January 7, 2025

- Most recent Technical FAQ version published (prior to March 9, 2026 update)

Suggested considerations

• *For all lenders:
• *Verify LTV compliance calculations for all new residential mortgage originations using the framework specified in the FAQ, ensuring own funds are calculated as actual equity contributions from borrowers
• *Implement dual LTV tracking for borrowers financing new property through sale of existing property, ensuring compliance with both interim and final LTV ratios
• *Document own funds sources carefully, particularly when cash collateral or sale proceeds are used, as these are only permitted for loans with initial LTV below 100%
• *Prepare for June 30, 2025 transition by:

What changed

• The most recent update (March 9, 2026) to the Technical FAQ reflects the regulatory framework established by CSSF Regulation No 20-08 (as modified by Regulation No 24-10).
• First-time buyers: LTV limit of up to 100%
• Other buyers: LTV limit of 90%, implemented via portfolio allowance Buy-to-Let Residential Loans:
• Standard LTV limit of 80%
• Temporary exemption (until June 30, 2025): Lenders may apply LTV ratios up to 95% for up to 10% of annual production Other Residential Real Estate Loans:

Key dates

17 Dec 2018

Original Circular CSSF 18/703 published; reporting obligation introduced

19 Feb 2020

Circular CSSF 20/737 and FAQ published; clarified exemptions and scope

10 May 2021

Circular CSSF 21/772 amendment published

25 Mar 2026

Circular CSSF 26/908 amendment published (today's date); immediate implementation expected for upcoming cycles

Ongoing (semi Deadline

annual); Reports due in April (ref. 31 Dec) and October (ref. 30 Jun) each year

Suggested considerations

• Download and use the dedicated RRE data template from the CSSF website (https://www.cssf.lu/en/Document/circular-cssf-18-703/).
• Assess total outstanding RRE exposure; if > EUR 10 million, collect data on new/outstanding exposures per reference dates (30 Jun/31 Dec).
• Ensure IT systems store/process RRE indicators (e.g., borrower debt metrics, collateral details) for semi-annual extraction.
• Submit reports to CSSF in April/October; review amendments (20/737, 21/772, 26/908) and FAQ for updates.
• For exempt banks: Confirm eligibility annually; no zero report required.

What changed

• - Original Scope (CSSF 18/703, 17 Dec 2018): Requires semi-annual reporting of RRE indicators for loans secured by Luxembourg residential real estate (existing dwellings, under construction,...
• Amendment CSSF 20/737 (19 Feb 2020): Clarified reporting thresholds and processes; banks with total outstanding RRE exposure ≤ EUR 10 million are exempt from reporting (no zero report needed if no...
• FAQ (19 Feb 2020): Specifies reporting for new exposures (Jan-Jun or Jul-Dec) and outstanding exposures as of 30 June/31 Dec; exemption applies only if exposure < EUR 10 million.
• Amendment CSSF 21/772 (10 May 2021): Further refinements to data template and indicators.
• Amendment CSSF 26/908 (25 Mar 2026): Latest update to reporting template and processes, effective immediately given publication date. Data is collected via a CSSF template on the website, focusing on...

Key dates

24 March 2025

- CBI publishes revised CPC 2025, Standards for Business Regulations, Consumer Protection Regulations, and guidance

24 March 2026

- CPC 2025 takes effect; existing 2012 Code ceases (12-month implementation period ends)

Until 24 March 2026

- 2012 Code (with addenda) remains in force

Suggested considerations

• Gap analysis: Map current policies/processes against CPC 2025 using CBI's mapping tool; update for new obligations like digital service design, vulnerability screening, fraud measures.
• Policy/system updates: Implement "secure customers’ interests" framework; enhance disclosures (e.g., mortgages, charges, unregulated activities); train staff on conduct standards/vulnerable consumers.
• Governance/risk: Strengthen board oversight, risk management for cyber/fraud/digital risks; distinguish regulated/unregulated activities.
• Testing/monitoring: Develop records/compliance systems; test advertising/bundling; integrate sustainability claims checks.
• Stakeholder engagement: Review CBI guidance/FAQs; prepare for supervision during implementation.

What changed

• The CPC 2025 comprises Standards for Business Regulations (governance, resources, risk management, conduct standards) and Consumer Protection Regulations (cross-sectoral and sector-specific rules for...
• Core obligation: Firms must "secure customers’ interests," shifting to a proactive, customer-focused mindset.
• Cross-sectoral requirements: Knowing the consumer/suitability; conflicts of interest/remuneration; vulnerable consumers (updated definition); digitalisation (customer-focused design); effective...
• Specific enhancements: Fraud/scam protections; mortgage switching disclosures; greenwashing prevention via clear sustainability claims; expanded consumer definition (e.g., SMEs up to €5m turnover...
• Supporting materials: Guidance on securing interests/vulnerable consumers, mapping tool for legacy codes, redline amendments.

Key dates

2024

FCA letter to CEOs of Annex 1 firms raising AML concerns.; - **Late 2025 - FCA follow-up engagement with 300 Annex 1 firms.**

Suggested considerations

• Verify Annex 1 registration status directly from the firm and via independent checks (e.g., FCA Register).
• Understand the Annex 1 firm's business model, products, and risks, aligning with MLRs and 2025 NRA.
• Manage identified risks, such as AML deficiencies or consumer encouragement into limited company structures for unregulated lending.
• Document due diligence to demonstrate compliance, integrating into broader financial crime frameworks (e.g., BWRA/CRA per FCA findings).

What changed

No new rules or legislative changes are introduced; this is a supervisory reminder reinforcing existing obligations under the Money Laundering Regulations 2017 (MLRs). It emphasizes enhanced due diligence on Annex 1 firms, referencing the 2025 National Risk Assessment (NRA) for risk management. The FCA highlights proactive engagement, including a 2024 letter to CEOs and follow-up with 300 firms in late 2025, signaling intensified supervision without altering the registration-only regime under the Financial Services and Markets Act.

Key dates

25 February 2026

- MFS entered administration

20 March 2026

- FCA enforcement investigation opened (current date context)

No specific deadline provided Deadline

for investigation completion or enforcement action

Suggested considerations

• *For MFS and its Administrators:
• Cooperate fully with the FCA enforcement investigation
• Preserve all documentation related to AML/CTF compliance, customer due diligence, and transaction monitoring
• Provide access to bank accounts, transaction records, and compliance files to investigators
• Respond to FCA information requests within specified timeframes

What changed

• The FCA's enforcement investigation does not introduce new regulatory requirements but rather represents the regulator's response to alleged breaches of existing obligations.
• Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017: MFS's primary regulatory obligation as an Annex 1 registered firm.

Key dates

Before end of 2026

- Consumers expected to begin receiving compensation under motor finance scheme

End of March 2026

- FCA expected to publish final rules and guidance for motor finance redress scheme, confirming scope, calculation methodologies, and timescales

31 May 2026 Deadline

- Complaints pause lifts for DCA-related motor finance complaints; standard 8-week response deadline resumes

Mid

2026 onwards; - Motor finance compensation payments anticipated to commence

Suggested considerations

• *Immediate Operational Priorities (Pre-May 2026):
• *Governance and Accountability
• Appoint senior managers with explicit accountability for complaints handling and redress programmes
• Establish board-level oversight structures with regular reporting on complaints volumes, redress calculations, and regulatory compliance
• Document decision-making frameworks for complaint eligibility and dismissal grounds

What changed

The redress system modernization introduces several structural and procedural reforms: Registration Stage for Complaints A new formal registration stage has been introduced to standardize how complaints enter the system, improving tracking and early identification of systemic issues across firms and markets. Updated Dismissal Grounds The FCA has revised the criteria for dismissing complaints, providing clearer standards that should reduce disputes about complaint admissibility and improve consistency in decision-making. Enhanced Fair and Reasonable Test Guidance Clearer guidance on how the...

Key dates

2021

Regulatory change introduced prohibiting debtor assignment for guaranteed receivables; .[ECB Press Release]

Q1 2021 to Q4 2024 (13 consecutive quarters)

Period of breaches by Nordea Finance Finland Ltd; .[ECB Press Release]

10 March 2026

ECB announces €2.26 million penalty; .[ECB Press Release]

Suggested considerations

• Review Exposure Calculations: Immediately audit methodologies for guaranteed receivables, ensuring assignment to guarantors per 2021 rules; validate against CRR connected client principles.[ECB Press Release]
• Enhance Internal Controls: Implement robust governance to prevent "serious negligence," including automated checks, independent validation, and training on counterparty identification.[ECB Press Release]
• Conduct Gap Analysis: Test large exposure reporting for the past 4 years; remediate any breaches within EBA timelines (e.g., return to compliance promptly).
• Monitor and Report: Establish real-time monitoring for exposures >10% capital; notify ECB of breaches immediately with remediation plans.[ECB Press Release]
• Penalty Challenge Option: Affected firms may appeal to the Court of Justice of the European Union within standard timelines (typically 2 months).[ECB Press Release]

What changed

• - 2021 Regulatory Change: Prohibits assigning guaranteed receivables to debtors for large exposure calculations; exposures must be assigned to guarantors instead, ensuring proper risk attribution to...
• Large Exposure Limits (CRR): Exposures exceeding 10% of a bank's capital trigger reporting as "large"; no single exposure or group of connected counterparties may exceed 25% of capital.
• Severity Classification: ECB categorizes breaches as "severe" (from minor to extremely severe), guiding penalty calculations per its *Guide to the method of setting administrative pecuniary...
• Broader Framework: EBA Guidelines on large exposures provide criteria for assessing breaches and timelines for returning to compliance, emphasizing harmonized EU application.

Key dates

Early 2026

– Scheme implementation begins (exact date dependent on final rules publication)

Late March 2026

– FCA to publish final scheme rules (timing to be confirmed in advance, outside market hours)

31 May 2026 Deadline

– Motor finance complaints handling pause lifts; firms must be ready to respond to complaints outside the scheme

11 April 2031 Deadline

– Record retention deadline for all relevant scheme documentation

Three months from scheme launch

– Standard implementation period for lenders to contact prior complainants and provide compensation notifications

Suggested considerations

• *Immediate Priorities (Q1 2026):
• *Data Integrity Assessment: Conduct comprehensive audit of historic motor finance agreements to identify eligible customers and validate transactional data completeness, particularly for older agreements.
• *Redress Calculator Development: Build auditable, validated redress calculators capable of:
• Repricing loans based on proposed APR reductions
• Calculating compensatory interest at BoE base rate + 1%

What changed

• The FCA's streamlined approach introduces several material modifications to the original compensation scheme proposal: Process Streamlining
• Automatic opt-in for prior complainants: Customers who complained before scheme launch will no longer be asked to opt out.
• Immediate acceptance of offers: Consumers can accept redress offers immediately rather than waiting for final determinations.
• Flexible communication channels: Firms are no longer required to use recorded delivery; alternative channels with fraud safeguards are permitted. Implementation Timeline
• Three-month standard implementation period from scheme launch, with up to five months for older agreements to allow adequate data review and calculation accuracy.

Key dates

24 October 2025 Deadline

- Consultation response deadline for CP13/25

20 February 2026

- Publication date of PS5/26 (final policy)

~20 August 2026 Deadline

- Implementation deadline for SS2/23 CUSO expectations (six months from PS5/26 publication)

Suggested considerations

• Review and update policies: Credit unions must conduct due diligence/risk assessments before any CUSO investment/use; implement conflict of interest policies, especially for non-credit union partnerships.
• Ensure structural safeguards: Limit liability to investment amount; maintain legal/operational separation between credit union and CUSO; monitor aggregate investments ≤7.5% of capital.
• Governance alignment: Decisions must prioritize member benefits per legislative objects; update internal investment rules to comply with amended PRA Rulebook (Credit Unions Part).
• Implementation planning: Within six months, integrate SS2/23 expectations into operations; non-engaging credit unions need no action but should monitor for opportunities.
• Reporting/oversight: Prepare for PRA supervision on CUSO risks; consider CBA updates if significantly impacting mutuals.

What changed

• - Investment permission and cap increase: Credit unions can now invest in CUSOs using own capital, with the cap raised from 5% to 7.5% of total capital across all CUSOs (clarifications added on...
• Expanded CUSO scope: CUSOs can now serve other UK-regulated mutuals (with Part 4A permission) beyond just credit unions; partnerships with non-credit unions permitted as owners, subject to safeguards.
• Supervisory expectations in SS2/23: New chapter requires due diligence, risk analysis, limited liability to investment amount, legal/operational separation, conflict of interest policies, and...
• Other updates: Chapter 17 of SS2/23 amended due to deletion of SS20/15; six-month implementation window for SS2/23 CUSO expectations.

Key dates

4 November 2025

- EBA Guidelines (EBA/GL/2025/03) apply across EU (two months post-publication on 27 June 2025 in all official languages)

1 December 2025 Deadline

- CSSF Circular 25/899 published, requiring immediate compliance preparation for Luxembourg firms

Suggested considerations

• Review and classify ADC exposures against EBA-defined criteria (e.g., contract thresholds, equity levels, monitoring standards) to determine eligibility for 100% risk weight.
• Update internal policies, risk assessment models, and credit approval processes to incorporate "sound lending standards" and EBA specifications, including social housing carve-outs.
• Recalculate capital requirements under standardized credit risk approach; report changes via CRR disclosures.
• Maintain documentation proving compliance (e.g., deposit proofs, equity valuations) for supervisory audits by CSSF.
• Institutions must "make every effort to comply" per EBA Regulation Article 16(3).

What changed

• - Introduces precise definitions for CRR Article 126a(2) terms, enabling 100% risk weight (instead of 150%) for ADC exposures to residential property if conditions are met: at least 50% of total...
• Mandates "sound standards for lending and credit monitoring" alongside these criteria.
• Accounts for social housing/public not-for-profit lending specificities, with tailored rules for regulated entities serving long-term tenant housing.
• Replaces prior "particularly high-risk exposure" class with dedicated ADC class under CRR3.

Suggested considerations

• Review and update policies: Building societies must confirm internal treasury/lending frameworks align with remaining requirements (e.g., PRA Rulebook, Building Societies Act 1986, ICAAP/SREP under amended SS31/15); remove any SS20/15-specific references or processes.
• Assess risk management: Evaluate use of derivatives or treasury tools for compliance with non-prescriptive expectations; ensure SMCR accountability and board oversight.
• Update governance documents: Revise ICAAP/SREP processes per SS31/15 amendments; document rationale for tailored approaches to demonstrate proportionality.
• Engage supervisors: No immediate reporting mandated, but proactive dialogue recommended for firms previously on extensions or complex approaches.
• Monitor related reforms: Track Strong and Simple framework (e.g., PS4/26, PS20/25) for SDDT capital/liquidity simplifications referencing this change.

What changed

• - Full deletion of SS20/15: Removes all expectations on treasury and lending activities, including the "Treasury Approaches" framework, without replacement.
• Consequential amendments: Updates SS31/15 (Internal Capital Adequacy Assessment Process and Supervisory Review and Evaluation Process) to excise references to SS20/15.
• Alignment with broader policy: Addresses inconsistencies with PRA's approach for banks, improved sector risk management maturity, and proportionality for smaller firms; supports objectives of safety,...
• No new rules imposed: PRA deems existing tools sufficient, including Building Societies Act 1986 restrictions, PRA Rulebook, SMCR, and supervision; derivatives permitted only for risk management...

Key dates

5 March 2025

- PRA publishes Consultation Paper CP2/25 proposing £70 billion threshold

5 June 2025 Deadline

- Consultation response deadline

12 November 2025

- PRA issues PS22/25 with final policy

1 January 2026

- Final policy takes effect, applying new £75 billion threshold and three-year averaging

30 June 2026

- Cessation of modifications by consent disapplying leverage ratio rules

Suggested considerations

• Review and update internal retail deposits calculations to incorporate three-year moving average methodology starting 1 January 2026.
• Assess current and projected retail deposits against £75 billion threshold (and £10 billion non-UK assets) to determine leverage ratio applicability and adjust capital planning accordingly.
• Prepare to meet 3.25% leverage ratio minimum plus buffers if thresholds breached, including systems updates for averaging and reporting.
• For firms with modifications by consent: Plan transition back to full leverage ratio rules by 30 June 2026, including any necessary capital raises or disclosures.
• Update governance, risk models, and board reporting to reflect changes; conduct gap analysis against PRA Rulebook appendices in PS22/25.

What changed

• - Retail deposits threshold raised from £50 billion to £75 billion, adjusted upward from the CP2/25 proposal of £70 billion to account for further GDP growth to Q2 2025 (rounded to nearest £5...
• Introduction of a three-year moving average for calculating retail deposits metric, replacing point-in-time values to mitigate volatility and aid capital planning, particularly for building societies.
• Non-UK assets threshold remains unchanged at £10 billion.
• Modifications by consent disapplying leverage ratio rules during review will cease on 30 June 2026. These changes are implemented via updates to the Leverage Ratio – Capital Requirements and Buffers...