Reporting & Disclosure in United States

Key dates

2026-11-06

The final rule was published in the Federal Register at 91 FR 69955.

2027-02-04

Amendments to Investment Company Act rule 0-10 and Advisers Act rule 0-7 become effective.

2027-02-04 Deadline

The amendments to Advisers Act rule 203-3(b) and Form ADV become effective and compliance is required.

Suggested considerations

• Compliance teams may wish to assess whether the adviser or any relevant control group will qualify as a small entity under the revised less-than-$1 billion RAUM test once the amendments become effective.
• Advisers may wish to review Form ADV Item 12 procedures, reporting logic, and filing controls so that the revised definition is applied from the February 4, 2027 compliance date.
• Advisers and fund groups may wish to map control relationships and family-of-investment-companies aggregation methodology against the amended thresholds rather than treating each legal entity independently.
• Firms may wish to confirm that internal policies do not incorrectly treat the revised RFA thresholds as changes to SEC registration, exemption, fiduciary, reporting, custody, or other substantive obligations.
• Advisers relying on or considering a continuing hardship exemption may wish to review the conforming amendments to Advisers Act rule 203-3(b) and update related filing documentation.
• Regulatory-change inventories and future rulemaking impact assessments may benefit from recording the inflation-adjustment mechanism and monitoring subsequent Commission adjustment orders.

What changed

Effective February 4, 2027, rule 0-10 will increase the threshold for a registered investment company or business development company to qualify as a small entity from $50 million to $10 billion of net assets. Asset aggregation will use the Form N-CEN concept of a family of investment companies rather than the former group of related investment companies terminology.

Key dates

2026-11-04

The SEC adopted the amendments to Rules 0-10, 0-7, 203-3 and related Form ADV provisions.

Suggested considerations

• Compliance teams may wish to reassess the firm's status under Advisers Act Rule 0-7 and Investment Company Act Rule 0-10 using current Form ADV regulatory assets under management, fund-family relationships, net assets, and control relationships.
• Advisers and fund groups should distinguish the revised Regulatory Flexibility Act small-entity classification from SEC registration thresholds, eligibility for regulatory exemptions, and other substantive compliance obligations; the amendments do not alter those requirements.
• Fund administrators and regulatory reporting teams should review family-of-investment-companies aggregation data against Form N-CEN Item B.5 and prepare to apply the revised aggregation methodology when the amendments become effective.
• Advisers that rely on or may need a continuing hardship exemption from electronic filing should review the related Rule 203-3 and Form ADV amendments and confirm procedures, systems, and filing calendars before the compliance date.
• Compliance teams may wish to monitor the Federal Register for the publication date and calculate the 90-day effective and compliance date, since the SEC release does not yet provide a calendar date for that event.
• Regulatory policy teams should consider whether the broader small-entity population changes how the SEC's future rulemakings and Regulatory Flexibility Act analyses may affect the firm's cost and burden profile, without assuming that the classification creates immediate operational relief.

What changed

Rule 0-10 increases the net-asset threshold for an investment company, including a business development company, to $10 billion from $50 million and replaces the existing related-fund aggregation approach with a reference to a family of investment companies as used in Form N-CEN Item B.5. Rule 0-7 increases the investment-adviser small-entity threshold to less than $1 billion of regulatory assets under management from $25 million, eliminates the separate investment-adviser total-assets threshold, and makes conforming changes to the control-relationship tests.

Key dates

2020-04-27

NCUA published the interim final rule establishing the PPP risk-weighting, PPP Loan Facility total-asset exclusion, and commercial-loan treatment.

2022-01-01

NCUA’s 2015 risk-based capital final rule became effective; the December 2021 final rule had already carried forward the relevant PPP treatment into the then-current capital adequacy framework.

2026-11-04

The final rule adopting the April 27, 2020 IFR without change becomes effective and is published at 91 FR 69493.

Suggested considerations

• Compliance teams may wish to confirm that risk-based capital reporting continues to assign a 0 percent risk weight only to loans meeting the applicable SBA PPP eligibility and coverage criteria.
• Credit unions that pledged PPP loans to the Federal Reserve PPP Loan Facility may wish to verify that the loans remain appropriately identified and excluded from total assets solely for the net worth ratio calculation under 12 CFR 702.2.
• Regulatory reporting and finance teams may wish to reconcile PPP-loan classifications across the general ledger, capital calculations, Call Report processes, and supporting documentation.
• Lending compliance teams may wish to confirm that qualifying PPP loans are not included as commercial loans for purposes of 12 CFR part 723, while other applicable lending, documentation, servicing, SBA-guarantee, and record-retention requirements remain separately addressed.
• Credit unions may wish to retain evidence supporting SBA guarantees, facility pledges, non-recourse funding, and the basis for any regulatory capital exclusions, particularly where legacy PPP balances remain on the balance sheet.
• Policy owners may wish to update regulatory inventories to identify the 2026 rule as a finalization of the 2020 IFR rather than as a new operational requirement.

What changed

Under 12 CFR part 702, covered loans issued under the SBA Paycheck Protection Program continue to receive a 0 percent risk weight for risk-based capital purposes. PPP loans pledged as collateral for a non-recourse borrowing through the Federal Reserve’s PPP Loan Facility continue to be excluded from total assets when calculating the net worth ratio under 12 CFR 702.2. Under 12 CFR part 723, PPP loans remain excluded from the definition of commercial loans.

Key dates

2026-11-04

The proposed rule was published in the Federal Register at 91 FR 69642.

2027-01-04 Deadline

Comments on RIN 3064-AG35 must be received by the FDIC.

2029-10-01

First proposed inflation-based adjustment to the section 360.9 covered-institution and larger-covered-institution thresholds.

Suggested considerations

• Affected banks should assess whether they meet the proposed covered-institution or larger-covered-institution thresholds using Call Report definitions and current deposit-account and asset data.
• Current part 370 institutions should map existing output files and deposit-account records against the 26 proposed mandatory fields in 12 CFR part 360 appendices C through G, identifying gaps in account title, ownership, relationship, beneficiary, domestic-versus-foreign, and other required data.
• Part 370 institutions should evaluate the effect of replacing their own deposit-insurance calculation systems with FDIC-calculation reliance, while preserving or redeveloping the provisional-hold capabilities required by proposed section 360.9.
• Larger covered institutions should inventory transactional accounts subject to the proposed account-holder contractual or disclosure requirement and determine which mortgage-servicer, fiduciary, real-estate, IOLTA, employee-benefit-plan, and trust-related accounts may be excluded.
• Compliance, operations, legal, and technology teams should review the proposed six-month implementation period for general requirements and 18-month period for provisional-hold requirements for institutions that are larger covered institutions on the final rule's effective date.
• Banks approaching the thresholds should establish monitoring for two consecutive quarters, the proposed 12-month implementation period after becoming a larger covered institution, and the proposed release mechanism after three consecutive quarters below the relevant threshold.
• Institutions should consider whether to submit comments by January 4, 2027, particularly on field-level data requirements, provisional-hold redevelopment, account-holder disclosures, transition timing, exemptions, and the CPI-W indexing methodology.
• Industry commentary indicates that the proposal is being read primarily as a burden-reduction measure for large banks, with estimated annual savings of approximately $33 million offset by approximately $14 million in transition costs; firms should nevertheless account for operational work associated with standardized data and provisional holds.

What changed

Proposed revised 12 CFR 360.9 would apply to insured depository institutions with at least $2 billion in deposits and either at least 250,000 deposit accounts or at least $20 billion in total assets, regardless of deposit-account count. A new category of larger covered institution would include institutions with at least $2 billion in deposits and two million or more deposit accounts. Part 370 institutions would generally become larger covered institutions under section 360.9, and would no longer need to operate systems capable of calculating deposit-insurance coverage themselves.

Key dates

2023-12-13

The SEC adopted the Treasury clearing amendments, including the trade-submission requirement implemented through Exchange Act Rule 17ad-22(e)(18)(iv)(A).

2026-10-30

The SEC issued exemptive relief for specified inter-affiliate and non-U.S. Treasury repo transactions.

2026-12-31 Deadline

Compliance date for applicable eligible secondary market cash transactions involving U.S. Treasury securities.

2027-06-30 Deadline

Compliance date for applicable eligible secondary market repo transactions involving U.S. Treasury securities.

Suggested considerations

• Firms should obtain and analyze the operative October 30, 2026 Section 36 exemptive order, including all limits, conditions, definitions, recordkeeping provisions, and any continuing reporting requirements.
• Compliance teams may wish to inventory all Treasury repo transactions by legal entity, counterparty location, direct-participant status, affiliate relationship, guarantee structure, and whether the transaction is market-facing or solely inter-affiliate.
• Firms should validate whether each proposed affiliate qualifies under Rule 17ad-22(a) as modified by the relief and confirm that the affiliate is not an investment company under Section 3 of the Investment Company Act of 1940.
• Broker-dealers and other direct participants should update trade-classification, order-management, confirmation, clearing-submission, exception-management, and surveillance controls to distinguish exempt transactions from transactions that must be submitted for clearing.
• Global firms should establish governance for monitoring any activity-based or volume-based limit applicable to non-U.S. repo relief, including data ownership, aggregation across affiliates and direct participants, calculation frequency, escalation thresholds, and evidence retained for supervisory review.
• Firms should continue implementation of the broader Treasury clearing framework and should not treat the relief as a basis for delaying preparations for the December 31, 2026 cash-market or June 30, 2027 repo compliance dates.
• Legal and compliance teams may wish to assess whether non-U.S. branches, foreign affiliates, guarantees by U.S. persons, or local-law requirements create additional obligations notwithstanding the SEC relief.

What changed

The relief applies to certain repo transactions involving non-U.S. counterparties, subject to specified limits and conditions. It also expands the inter-affiliate treatment for repos between a direct participant of a U.S. Treasury securities covered clearing agency and an affiliated entity that is not an investment company under Section 3 of the Investment Company Act of 1940, provided the affiliate otherwise meets the affiliated-counterparty definition in Rule 17ad-22(a).

Key dates

2026-10-30

FDIC Board unanimously approved the Notice of Proposed Rulemaking by notational vote.

Suggested considerations

• Compliance teams should obtain and review the complete NPRM, including proposed amendments, definitions, scope thresholds, transition provisions, and the Federal Register comment deadline, because the bulletin itself contains only a high-level announcement.
• Firms should map each insured depository institution against the current applicability criteria in 12 CFR part 370 and 12 CFR 360.9, documenting deposit-account counts, domestic deposits, total assets, existing exemptions, certifications, and any voluntary compliance elections.
• Affected institutions should inventory overlapping deposit-insurance determination, depositor-record, provisional-hold, data-format, and reporting capabilities to identify systems that could potentially be consolidated if the proposal is finalized.
• Technology, operations, deposit administration, legal, resolution-planning, and third-party-risk teams should assess whether current data lineage, account ownership and capacity coding, reconciliation, testing, and FDIC access processes would satisfy a revised standardized-record framework.
• Firms should consider submitting comments on the operational feasibility, treatment of affiliates and mergers, transition periods, testing expectations, treatment of custodial and pass-through accounts, and whether any proposed relief would create gaps in failure-day data availability.
• Institutions should continue complying with currently effective 12 CFR part 370 and 12 CFR 360.9 requirements until a final rule becomes effective and any applicable transition period expires.

What changed

The FDIC has proposed amendments concerning the framework used by large insured depository institutions to maintain depositor records and support rapid deposit-insurance determinations. Based on the FDIC’s accompanying policy direction and independent industry commentary, the proposal would likely preserve standardized depositor-record and data-access requirements while reducing or eliminating the need for institutions subject to 12 CFR part 370 to maintain separate, independent deposit-insurance determination systems.

Key dates

2026-10-29

The SEC announced charges against BG Wealth Sharing Ltd and DSJ Exchange Pty Ltd and filed the related enforcement complaint in the U.S. District Court for the Northern District of California.

Suggested considerations

• Compliance teams may wish to review third-party crypto platforms, advisers, issuers, introducers, and promoters for unsupported claims that an SEC filing represents licensing, approval, endorsement, or authorization.
• Firms should consider independently verifying Form ADV, Form D, and other regulatory filings through official regulator databases and documenting the precise legal effect of each filing before relying on it in due diligence or investor communications.
• Marketing and financial-promotion controls may wish to test for claims of risk-free or guaranteed returns, extraordinary monthly performance, government approval, SEC registration, fake certificates, and statements that a Rule 506(c) filing authorizes operation of a crypto exchange.
• Firms with exposure to BG Wealth Sharing, DSJ Exchange, or associated promoters should consider escalating the relationship for legal, fraud, sanctions, counterparty, and suspicious-activity review and preserving relevant communications, transaction records, and onboarding materials.
• Investment advisers and other regulated firms may wish to assess whether referral, custody, payment, or platform relationships involving similar schemes create customer-protection, books-and-records, disclosure, or reputational risks.
• Compliance teams may wish to incorporate the related state and foreign warnings into typology monitoring, particularly indicators such as recruitment-based compensation, blocked withdrawals, advance exit or compliance fees, fake account balances, and periodic payments used to sustain investor confidence.

What changed

This is an enforcement action, not a new rule or generally applicable compliance requirement. The SEC alleges violations of the antifraud provisions of the Securities Act of 1933 and Securities Exchange Act of 1934 by both entities, and violations of Sections 204(a) and 207 of the Investment Advisers Act of 1940 by BG Wealth. The SEC is seeking permanent injunctions, disgorgement with prejudgment interest, civil penalties against both entities, and conduct-based injunctions against BG Wealth.

Key dates

2026-10-28

FOMC statement released; target federal funds range maintained at 3.75% to 4.00% and ample-reserves policy continued.

Suggested considerations

• Compliance and risk teams may wish to record the October 28, 2026 target range of 3.75% to 4.00% and the 10-2 vote in regulatory change-management and market-risk records.
• Firms should consider reviewing interest-rate, basis, liquidity and funding-risk limits against scenarios involving a further 25-basis-point increase, including a possible December 2026 hike suggested by independent market commentary.
• Banks and other lenders may wish to assess the effect of persistently elevated rates on borrower affordability, refinancing risk, delinquency assumptions, fair-lending monitoring and customer communications.
• Treasury and finance teams should consider validating the treatment of the unchanged policy rate in transfer-pricing, liquidity-stress, valuation, hedge-accounting and capital-planning models.
• Broker-dealers, asset managers and leveraged funds may wish to reassess margin, collateral, redemption-liquidity and counterparty exposures under higher-for-longer rate scenarios.
• Compliance teams should consider monitoring the forthcoming FOMC implementation note and subsequent Federal Reserve communications for any operational details affecting reserve management or money-market conditions.
• Firms should consider documenting the distinction between this policy decision and a new regulatory rule: the statement contains no new prudential ratio, disclosure, reporting or customer-protection requirement.

What changed

The FOMC made no change to the federal funds target range, which remains 3.75% to 4.00%, and did not announce a change to its policy of maintaining ample reserves in the banking system. The statement upgraded its description of economic activity to expanding at a strong pace and characterized productivity growth and capital investment as strong or robust, while stating that inflation remains elevated. The Committee emphasized that it will assess additional information in determining the policy stance needed to return inflation to its 2% goal. Lisa D. Cook and Beth M.

Key dates

2026-10-21

OCC publishes Bulletin 2026-52, revised PS-01 and PS-02 forms for public comment, and issues its GENIUS Act implementing final rule.

2027-01-18

The OCC final rule implementing the GENIUS Act and the GENIUS Act take effect, according to the OCC’s related final-rule materials.

2027-01-25 Deadline

First weekly PS-01 report date, subject to OMB approval of the information collection.

2027-03-31 Deadline

First quarterly PS-02 report date, subject to OMB approval of the information collection.

Suggested considerations

• Compliance teams at affected issuers should review the revised PS-01 and PS-02 workbooks and instructions and identify every required data element, reporting frequency, aggregation rule, and responsible control owner.
• Firms should consider submitting comments within 30 days after publication of the information-collection notice in the Federal Register, with particular attention to data availability, calculation methodology, confidentiality, reporting burden, and transition timing.
• Issuers should map daily issuance, redemption, reserve, ownership-concentration, and trading data to PS-01 and test whether systems can produce a complete weekly submission for the January 25, 2027 report date, subject to OMB approval.
• Issuers should assess whether finance and regulatory-reporting systems can produce PS-02 information on income, assets, liabilities, off-balance-sheet activities, and capital for the March 31, 2027 report date.
• Firms should establish governance for data certification, reconciliation to general-ledger and reserve records, exception management, senior review, and retention of supporting documentation for OCC examination.
• Issuers should assess the interaction between the reporting forms and the final rule’s reserve, redemption, risk-management, audit, capital, custody, and supervisory requirements, rather than treating the forms as an isolated reporting exercise.
• Foreign issuers should confirm their OCC registration status, reporting perimeter, U.S. activities, and allocation of information-production responsibilities between U.S. operations, parent entities, and service providers.

What changed

The OCC is reopening public comment on revised weekly Form PS-01 and quarterly Form PS-02 and their instructions. PS-01 requires daily data compiled and submitted weekly for each payment stablecoin, covering issuance, reserves, ownership concentration, and trading activity. PS-02 requires quarterly reporting on the issuer’s condition and income, including balance-sheet assets and liabilities, off-balance-sheet activities, income, and capital.

Key dates

2025-07-18

The GENIUS Act was enacted.

2026-10-21

The OCC published the final rule and related application, waiver and reporting materials.

2027-01-18 Deadline

The GENIUS Act and OCC final rule take effect; U.S. payment stablecoin issuance generally requires permitted payment stablecoin issuer status, and a substantially complete application must be pending by this date to support eligibility for an OCC waiver request.

2027-01-25

Proposed first weekly OCC reporting date, subject to OMB approval of the information collection.

2027-03-31

Proposed first quarterly OCC reporting date, subject to OMB approval of the information collection.

Suggested considerations

• Firms seeking permitted payment stablecoin status should consider mapping their licensing strategy, corporate structure and applicable OCC pathway under 12 CFR part 15 before 2027-01-18.
• Existing U.S. issuers that need transitional relief should consider submitting a substantially complete OCC application on or before 2027-01-18 and preparing a written waiver request promptly after the OCC begins accepting applications and waiver requests.
• Applicants should consider documenting business plans, management, reserve assets, issuance and redemption processes, capital and liquidity, risk management, third-party and shared-services arrangements, audit functions and compliance governance in the application package.
• Issuers should consider validating reserve composition, one-to-one backing, liquidity, concentration, counterparty exposure, stress-testing and redemption controls against the final rule rather than relying on the proposal's reserve assumptions.
• Issuers should consider testing operational capacity to process redemptions within two business days and to notify the OCC within 24 hours when the 10% redemption-demand trigger is reached.
• Issuers and distribution partners should consider reviewing stablecoin rewards, yield, rebate and promotional arrangements on a transaction-by-transaction basis because pre-existing programs are not automatically grandfathered and the final rule provides no general safe harbor.
• Covered firms should consider establishing governance for audits, reporting, examination responses, custody controls, foreign-issuer oversight and potential approval revocation or rescission.
• Compliance teams should track the separate Treasury-coordinated BSA, AML and OFAC rulemaking and avoid treating this final rule as the complete GENIUS Act compliance framework.

What changed

The final rule applies to national banks and their subsidiaries, federal savings associations and their subsidiaries, federal branches and their subsidiaries, federal qualified payment stablecoin issuers, foreign payment stablecoin issuers, and state qualified payment stablecoin issuers over which the OCC has regulatory or enforcement authority.

Key dates

2025-07-18

The GENIUS Act was enacted.

2026-10-21

The OCC published the final rule, application and waiver guidance, and revised proposed reporting forms.

2027-01-18 Deadline

The GENIUS Act and OCC final rule take effect; U.S. payment-stablecoin issuance generally requires permitted payment stablecoin issuer approval, and existing issuers seeking a waiver generally must have a pending substantially complete OCC application by this date.

2027-01-25 Deadline

Proposed effective report date for the weekly reporting form, subject to Office of Management and Budget approval.

2027-03-31 Deadline

Proposed effective report date for the quarterly reporting form, subject to Office of Management and Budget approval.

Suggested considerations

• Firms considering U.S. payment-stablecoin issuance should assess whether they qualify as a permitted payment stablecoin issuer, a federal qualified issuer, a state-qualified issuer subject to OCC authority, or a foreign issuer within the rule's scope.
• Existing U.S. issuers should consider preparing a substantially complete OCC application and evaluating whether a waiver request is needed by January 18, 2027; the OCC may grant waivers for up to 12 months beginning on that date, generally where an eligible application is pending.
• Applicants should prepare documentation covering the business plan, management, reserve assets, issuance and redemption processes, risk management, capital and liquidity, shared services, BSA/AML/OFAC controls, third-party risk, enterprise risk, compliance risk, and audit functions.
• Issuers should map reserve assets to the final rule's 1:1 backing, daily-liquidity, diversification, and counterparty-concentration requirements and establish controls capable of supporting generally timely redemption within two business days.
• Compliance and product teams should inventory interest, yield, cashback, loyalty, referral, and exchange rewards arrangements involving payment stablecoins and document the business purpose and consideration supporting each payment, because the OCC has not provided a categorical safe harbor and will apply the statutory prohibition case by case.
• Issuers should design weekly reserve and payment-stablecoin activity reporting and quarterly reports of condition and income, subject to confirming the final OMB-approved forms and effective reporting dates.
• Banks and other OCC-supervised custodians should review custody arrangements, segregation and control frameworks, third-party dependencies, and contractual allocation of responsibility for stablecoin and reserve-asset custody.
• Firms should track the separate Treasury, FinCEN, OFAC, Federal Reserve, and FDIC implementation work because the OCC final rule does not complete BSA, AML, or sanctions requirements and is only one component of the GENIUS Act framework.

What changed

New 12 CFR part 15 establishes requirements for permitted payment stablecoin issuers, foreign payment stablecoin issuers subject to OCC authority, certain state-qualified issuers, and specified custody activities conducted by OCC-supervised entities. The framework covers issuer activities, reserve assets, redemption, risk management, audits, reports, examinations, supervision, custody, applications and registrations, state-to-federal transitions, foreign-issuer supervision, approval revocation or rescission, and capital and operational backstops.

Key dates

2026-09-30

The SEC issued the proposed rule, Release Nos. 33-11444, 34-106534, and IC-36351; this is the underlying proposal date, not an effective date for new obligations.

2026-10-05

The proposed rule was published in the Federal Register at 91 FR 63388.

2026-10-20

The SEC published a correction replacing the DATES section and confirming the comment deadline.

2026-12-04 Deadline

Comments on the proposed rule must be received by the SEC.

Suggested considerations

• Compliance teams may wish to calendar December 4, 2026 as the deadline for submitting comments to File No. S7-2026-34 and coordinate comments across legal, fund governance, distribution, operations, and investor-relations functions.
• Affected fund sponsors should consider assessing whether monthly or otherwise revised repurchase intervals, delayed initial repurchase offers, or more frequent discretionary repurchases would better align with portfolio liquidity and investor-liquidity expectations if the proposal is adopted.
• Registered closed-end funds and BDCs considering multiple share classes should consider mapping proposed Rule 18f-3 and Rule 17d-3 conditions against existing exemptive orders, board procedures, fee arrangements, allocation methodologies, distribution agreements, and conflict controls.
• Fund boards and advisers may wish to evaluate the anticipated written multiple-share-class plan, board approval requirements, class-level expense allocation, asset-based distribution and service-fee arrangements, and related disclosure controls.
• Operations and disclosure teams should consider a gap analysis for proposed changes to Form N-2, Form N-CEN, Form N-23c-3, shareholder reports, prospectus legends, expense examples, NAV and repurchase processing, and investor communications.
• Firms should continue treating the current Investment Company Act rules and existing exemptive orders as controlling until any final rule becomes effective and applicable transition or rescission provisions are issued.

What changed

The October 20, 2026 Federal Register correction replaces the prior DATES text in the October 5 proposal and expressly states that the release was published on October 5, 2026 and that comments must be received by December 4, 2026. The underlying proposal would amend Investment Company Act Rules 23c-3, 18f-3, and 17d-3 and related forms and rules to modernize interval-fund repurchase programs, including potentially allowing a first repurchase offer to be deferred for up to two years, monthly repurchase intervals, annual discretionary repurchases, and deduction of deferred sales loads from...

Key dates

2026-10-09

SEC issued the proposed amendments to Investment Company Act Rule 17a-7, Release No. IC-36358, File No. S7-2026-36.

2026-10-15

Proposed rule published in the Federal Register; the 60-day public-comment period begins.

2026-12-14 Deadline

Public comments are due, calculated as 60 days after Federal Register publication.

Suggested considerations

• Compliance teams may wish to inventory current and potential cross trades by asset class and valuation level, distinguishing Level 1, Level 2, and Level 3 positions and identifying fixed-income portfolios that could become eligible.
• Advisers may wish to design a documented pre-trade best-interest process for each participating registered fund, including consideration of open-market alternatives, alternative securities, and the option not to trade.
• Funds and advisers may wish to assess pricing-source governance, including unaffiliated-source due diligence, periodic reasonableness reviews, NAV-pricing consistency, and controls preventing use of amortized-cost values.
• CCOs may wish to map quarterly review, annual back-testing, subsequent-sale analysis, escalation, and reporting responsibilities across fund and adviser compliance functions.
• Boards and counsel may wish to assess amendments to Rule 38a-1 policies, board reporting, and governance materials in light of the proposed shift away from board-adopted Rule 17a-7 procedures.
• Operations and regulatory-reporting teams may wish to map internal asset classifications to Form N-PORT Item B.12 and Form N-MFP Item A.23, including controls for the preceding-12-month activity test and reconciliation of cross-trade and total purchases and sales.
• Records-management teams may wish to evaluate systems capable of retaining trade records, CCO review materials, and board reports for six years.
• Interested parties may wish to submit comments by the Federal Register deadline, addressing the 79 specific requests for comment, including Level 3 eligibility, bid-side NAV pricing, review frequency, scaling, and public-reporting impacts.

What changed

Eligible securities would expand from generally Level 1 securities with readily available market quotations to securities valued using inputs that are observable directly or indirectly, provided Level 2 inputs are the lowest level of inputs significant to measurement; Level 3 securities would remain excluded. The proposed independent current market price would be either the value used in the fund’s next NAV calculation on the trade date or a price the adviser reasonably determines represents current market value using one or more unaffiliated pricing sources, subject to periodic review.

Key dates

2024-12-01

The OCC issued the December 2024 cease-and-desist order requiring Bank of America to address deficient BSA/AML controls; the publication does not specify the precise day of issuance.

2026-10-13

The OCC announced the $750 million civil money penalty and coordinated action with FinCEN.

Suggested considerations

• Compliance teams may wish to perform a documented gap assessment against 12 CFR 21.21 and 12 CFR 21.11, including transaction monitoring, customer and activity risk coverage, escalation procedures, SAR timeliness and accuracy, and recordkeeping.
• Banks should consider testing whether potentially suspicious activity is consistently escalated to appropriately skilled investigators and whether alert disposition processes can demonstrate timely decisions on SAR filing.
• BSA officers and relevant personnel should consider competency-based training covering suspicious-activity identification, investigation, SAR preparation, trade-based money laundering indicators, and escalation responsibilities, with evidence of completion and effectiveness testing.
• Internal audit and independent testing functions may wish to assess whether their scope, expertise, sampling, issue validation, and reporting are capable of detecting systemic BSA/AML weaknesses rather than merely confirming policy existence.
• Management and boards of directors should consider reviewing BSA/AML remediation governance, resourcing, milestones, risk acceptance, issue escalation, and the treatment of repeated or overdue corrective actions.
• Banks with material trade finance, correspondent banking, card, payments, or cross-border activity should consider targeted testing for trade-based money laundering typologies and transaction-monitoring coverage gaps.
• Institutions operating under a consent order or cease-and-desist order should consider independently validating that remediation is complete and effective, rather than relying solely on management representations or closure of project milestones.
• Compliance teams may wish to compare their control framework with the broader market reading of the action: industry reporting characterized the case as a record penalty driven by systemic and longstanding failures, while professional commentary on the evolving BSA/AML framework emphasizes the distinction between establishing an effective program and maintaining it in operation.

What changed

The publication is an enforcement action, not a new generally applicable rule or safe harbor. It establishes a major OCC enforcement precedent that persistent failures to implement an effective BSA/AML program after a formal supervisory order can result in exceptionally large penalties, including where deficiencies affect transaction monitoring, SAR escalation and filing, personnel competence, training, and audit effectiveness.

Key dates

2026-10-13

Federal Register publication date for the ANPRM, published as 91 FR 64811 and document number 2026-20888.

2026-12-14 Deadline

Deadline for submitting comments to the CFTC on Regulation CTX, Regulation CAM, and the interpretation and implementation of CEA section 2(c)(2)(D).

Suggested considerations

• Compliance teams may wish to determine whether current or planned retail crypto products could constitute transactions covered by CEA section 2(c)(2)(D), including products described as spot, margin, leveraged, financed, perpetual, or otherwise structured to defer delivery.
• Firms should consider mapping current customer agreements, funding arrangements, custody models, delivery controls, and liquidation processes against the CFTC's preliminary positions on offers and actual delivery.
• Prospective venues may wish to assess the potential CAM operating model, including registration perimeter, governance, listing standards, market surveillance, position controls, execution, recordkeeping, cyber and system safeguards, proof-of-reserves, and customer-asset arrangements.
• FCMs, IBs, DCOs, custodians, and leverage providers should consider identifying the registrations, permissions, capital, segregation, margin, clearing, insolvency, and operational dependencies that a CAM structure could create.
• Crypto businesses may wish to prepare comments addressing the scope of section 2(c)(2)(D), the definition and practical test for actual delivery, treatment of fully paid open transactions, permissible crypto assets, and the allocation of responsibilities among CAMs, FCMs, DCOs, and leverage providers.
• Firms should monitor whether the CFTC follows the ANPRM with a formal proposed rule and should not treat the ANPRM as creating immediate registration, margin, reporting, or conduct obligations.
• Affected firms may wish to preserve evidence of product design, delivery capability, customer disclosures, surveillance controls, and legal analysis in anticipation of supervisory or enforcement scrutiny under the CFTC's stated interpretation of section 2(c)(2)(D).

What changed

The CFTC has published ANPRM RIN 3038-AF80, 91 FR 64811, concerning proposed Regulation Crypto Asset Transactions and Regulation Crypto Asset Markets. Regulation CTX would seek to clarify when section 2(c)(2)(D) applies to crypto asset transactions, including the meaning of covered offers, actual delivery, and actual delivery of fully paid open transactions. Regulation CAM would create a crypto asset market subcategory of designated contract market registration under 17 CFR part 38, supported by related amendments or requirements under 17 CFR parts 1, 38, and 39.

Key dates

2026-10-09

CFTC announced publication of the NPRM concerning inclusion of certain event contracts in the definition of swap and identified a 30-day comment period beginning on Federal Register publication.

Suggested considerations

• Compliance teams may wish to inventory event contracts by underlying event, settlement structure, customer type, and current legal classification, including whether each product is a binary option, another swap, a future, a security-based swap, or a casino-style gambling product.
• Potential operators, DCMs, SEFs, registrants, trade associations, and affected customers should consider submitting written comments through Regulations.gov within 30 days after the NPRM is published in the Federal Register; the Federal Register publication date and resulting calendar deadline should be monitored because the CFTC release does not specify either date.
• Firms may wish to assess whether current exchange, venue, customer-eligibility, market-surveillance, anti-manipulation, product-certification, disclosure, margin, reporting, and recordkeeping controls would support treatment of relevant contracts as swaps under existing CFTC requirements.
• Operators currently relying on state licenses may wish to evaluate the potential need for DCM or SEF arrangements, CFTC registration, federal compliance infrastructure, and transitional management of overlapping state and federal obligations if the rule is finalized.
• DCMs and SEFs may wish to review product-listing governance against CEA section 5c(c)(5)(C), applicable core principles, and 17 CFR 40.2(c), including whether particular contracts are readily susceptible to manipulation or involve gaming or other activity contrary to the public interest.
• Legal and tax teams may wish to keep CEA classification separate from federal tax and information-reporting analysis, which the NPRM states will continue to depend on the Internal Revenue Code, Treasury regulations, and IRS guidance.
• Firms may wish to monitor the separate CFTC action concerning casino-style gambling products and assess how the two rulemakings interact for products near the boundary between event contracts and gambling wagers.

What changed

The NPRM, RIN 3038-AF82, would add proposed 17 CFR 1.3(Swap)(2)(i)(G): “Event contracts, including those based on sports-, politics-, cultural, and weather-related events.” The CFTC relies on several existing swap-definition provisions, including CEA section 1a(47)(A)(i), (ii), (iv), and (vi), covering options, transactions dependent on events with potential financial, economic, or commercial consequences, instruments commonly known as swaps, and combinations or permutations of covered instruments.

Key dates

2026-10-09

SEC issued the proposal to amend Investment Company Act Rule 17a-7.

Suggested considerations

• Compliance teams may wish to determine which corporate, municipal and other fixed-income holdings are currently excluded from Rule 17a-7 cross-trading because they lack a readily available market quotation under the valuation-rule framework.
• Firms should consider assessing potential execution-cost savings, liquidity benefits and conflicts risks from expanded internal crossing, using the SEC’s indication that market impact is concentrated among larger fund families and that corporate-bond cross-trading materially declined after the valuation-rule compliance date.
• Registered fund advisers may wish to review pricing governance, independent price verification, best-execution analysis, allocation controls and conflict-management procedures in anticipation of any final rule.
• Firms may wish to map the data needed for the proposed aggregated cross-trade reporting and test whether existing order-management, compliance-monitoring and regulatory-reporting systems can capture it.
• Affected firms should consider submitting comments during the 60-day period after publication of the proposal in the Federal Register, particularly on eligible security classes, pricing methodologies, reporting granularity and oversight conditions.
• Until a final rule becomes effective, firms should continue applying the existing Section 17(a), Rule 17a-7 and Rule 2a-5 requirements and should not treat the proposal as a current exemption.

What changed

The proposal would amend Rule 17a-7, the exemption from Section 17(a) for specified purchases and sales between a registered investment company and certain affiliated persons. It would generally restore eligibility for cross-trading most fixed-income securities, which became substantially unavailable after the SEC’s adoption of the Investment Company Act valuation rule in 2020, while modernizing the conditions governing pricing and oversight to reflect more verifiable and transparent market pricing.

Key dates

2026-10-08

Federal Reserve and OCC announced coordinated enforcement actions; the OCC imposed a $350 million civil money penalty on American Express National Bank and issued a cease-and-desist order. The Federal Reserve action applied to American Express Company and American Express Travel Related Services Company, Inc.

2027-01-06 Deadline

Approximate deadline for American Express National Bank to submit the OCC-required written Action Plan within 90 days of the October 8, 2026 order, subject to the order's day-counting conventions.

Suggested considerations

• Compliance teams may wish to reassess whether the institution's BSA/AML risk assessment adequately covers its largest and most economically significant products, customer segments, transaction channels, and trade-related activity.
• Firms should consider testing whether customer identification, customer due diligence, beneficial-ownership information, and transaction-monitoring scenarios are appropriately calibrated to credit-card, charge-card, merchant, cross-border, and trade-based money-laundering risks.
• Management may wish to inventory staffing, subject-matter expertise, escalation capacity, data quality, model and rules governance, internal controls, independent testing, and BSA/AML training for employees and directors against the deficiencies identified in the coordinated orders.
• Compliance teams may wish to conduct a lookback of previously generated alerts and transactions to assess whether suspicious activity was timely investigated, escalated, documented, and reported through SARs, including whether systemic monitoring gaps affected historical activity.
• Boards and senior management should consider obtaining documented evidence that enterprise AML oversight is operating effectively at subsidiaries and that parent-level governance does not rely solely on narrow subsidiary or product risk assessments.
• Affected American Express entities should track the 90-day Action Plan submission requirement and prepare supporting remediation evidence, governance reporting, milestone tracking, and supervisory communications.
• Other regulated firms should consider treating the action as a supervisory signal that risk assessments, transaction monitoring, and SAR controls must be aligned to actual business volume and risk rather than to the products that are easiest to administer.

What changed

This is an enforcement action rather than a generally applicable new rule, but it establishes concrete remediation expectations for a large, complex card issuer. The coordinated OCC order requires American Express National Bank to submit, within 90 days of the October 8, 2026 order, an acceptable written Action Plan addressing all BSA/AML deficiencies and incorporating the order's substantive requirements; the OCC must provide prior written supervisory non-objection.

Key dates

2026-10-08

The OCC announced the cease-and-desist order and $350 million civil money penalty against American Express National Bank; the Federal Reserve announced a coordinated action against American Express Company and American Express Travel Related Services Company.

Suggested considerations

• Compliance teams may wish to reassess whether the BSA/AML risk assessment accurately reflects the institution's largest and most complex products, customer segments, payment flows, geographies, channels, and transaction types, rather than relying primarily on deposit-account risk.
• Firms should consider testing whether customer identification, customer due diligence, beneficial-ownership information, and account-risk-rating processes provide sufficiently complete and reliable data for transaction monitoring and suspicious-activity reporting.
• Banks may wish to conduct a targeted lookback for trade-based money-laundering indicators in card, merchant, payment, cross-border, and related repayment activity, including activity involving insiders or connected accounts, and document escalation and reporting decisions.
• Compliance teams should consider validating that monitoring scenarios, alert thresholds, investigative workflows, case-management controls, quality assurance, and SAR filing processes can identify and report suspicious activity within applicable regulatory timeframes.
• Boards and senior management may wish to review whether BSA/AML staffing levels, expertise, reporting lines, technology, data governance, and independent-testing coverage are proportionate to the institution's size, complexity, and risk profile.
• Firms should consider strengthening role-based BSA/AML training for employees, directors, and senior management, with evidence of completion, competency, and periodic refreshers.
• Internal audit or another suitably independent function may wish to perform end-to-end testing of risk assessment, customer due diligence, monitoring, investigation, SAR decisioning, and governance controls, with tracked remediation and board-level reporting.
• U.S. banking organizations may wish to compare their programs against the OCC's findings and the market commentary emphasizing that the principal lesson is product-risk misalignment and the need for enterprise-wide controls, not merely remediation of isolated monitoring alerts.

What changed

This is an enforcement action and supervisory precedent, not a new generally applicable rule. The OCC required American Express National Bank to remediate a BSA/AML program that was not reasonably designed to assure and monitor compliance with the BSA and its implementing regulations. The findings specifically reinforce expectations that risk assessments cover the institution's actual product mix, including credit and charge cards; customer identification and customer due-diligence procedures support effective monitoring; transaction-monitoring and suspicious-activity reporting processes...

Key dates

2026-10-06

Vice Chair Bowman delivered the speech announcing the Federal Reserve's planned five-region supervisory realignment and outlining proposed modernization initiatives.

2026-07-01

The revised Community Bank Leverage Ratio framework took effect, lowering the ratio from 9 percent to 8 percent.

2025-12-01

The FFIEC issued a request for information on streamlining the Call Report.

Suggested considerations

• Compliance teams may wish to monitor Federal Reserve, FDIC, OCC, and FFIEC proposals arising from the speech, particularly any proposal to index fixed-dollar thresholds, revise community-bank classifications, modify large-bank tailoring, or amend Regulation O.
• Community banks should consider assessing how a future increase in the Community Bank Leverage Ratio eligibility threshold or broader community-bank treatment could affect capital planning, reporting, examination scope, and supervisory expectations; the speech does not yet establish eligibility changes beyond the 8 percent ratio already effective July 1, 2026.
• Banks preparing mergers may wish to document the competitive effects of credit unions, nonbank lenders, Farm Credit institutions, branchless banks, and other local competitors in anticipation of possible changes to Federal Reserve merger analysis.
• Prospective de novo applicants should consider reviewing business plans, initial and ongoing capital assumptions, governance arrangements, and expected approval timelines against existing federal and state requirements while awaiting any clarification of standards or conditional-approval practices.
• Call Report filers may wish to review the December 2025 FFIEC request for information and preserve data on duplicative, low-value, or operationally burdensome reporting items for future comment opportunities.
• Banks may wish to map current supervisory issues and examination findings to material financial risks, recognizing that the Statement of Supervisory Operating Principles emphasizes prompt escalation and proportionate action rather than checklist-driven process findings.
• Community banks should consider comparing their third-party risk-management programs with the Federal Reserve's community-bank third-party risk-management guide and documenting due diligence, contract oversight, ongoing monitoring, and escalation practices.
• Boards and senior management may wish to track forthcoming CAMELS revisions and assess potential effects on management-rating governance, examination preparation, remediation prioritization, and communications with directors.

What changed

The Federal Reserve announced that it is beginning to realign its supervisory function into five geographic regions led by regional leaders accountable for all supervisory activity in each region, while retaining existing Reserve Bank staff and footprints. The speech states that the Board will later in 2026 consider increasing fixed-dollar asset thresholds in its regulations and establishing a five-year adjustment mechanism tied to inflation and economic growth.

Key dates

2026-10-06

The proposed rule was published in the Federal Register at 91 FR 63676 and the comment period opened.

2026-12-07 Deadline

Comments on the proposed rule are due to the SEC.

Suggested considerations

• Compliance teams may wish to determine whether existing or proposed fund products could use the regulated-fund performance-compensation pathway and map each arrangement against the proposed 20% net-gains cap, specified-period methodology, governance requirements, and board-determination condition.
• Advisers and fund sponsors should consider inventorying current performance-fee arrangements and identifying clients who could become eligible under the proposed accredited-investor route, without treating the proposal as authority to implement changes before adoption and an applicable compliance date.
• Fund sponsors may wish to assess the operational and disclosure impact of separately reporting performance-based compensation in Forms N-1A, N-2, and N-CSR, including fee-table, prospectus, financial-reporting, and board-material changes.
• Adviser compliance programs should consider reviewing Rule 205-3 eligibility controls, investor-classification procedures, accredited-investor evidence, client look-through analysis, and controls for the related Rule 203A-3, Rule 204-3, and Form ADV amendments.
• Fund boards and advisers may wish to evaluate how performance-fee proposals would affect fiduciary-duty analysis, conflicts management, valuation, incentive alignment, investor communications, and approval documentation.
• Affected firms should consider submitting comments by December 7, 2026, particularly on the 20% cap, specified performance period, governance conditions, disclosure design, accredited-investor eligibility, and transition or compliance-period issues.

What changed

Proposed amendments to Investment Advisers Act Rule 205-3 would create an additional route for registered investment advisers to receive compensation based on capital gains or capital appreciation from registered management investment companies and business development companies, collectively referred to as regulated funds.

Key dates

2026-10-06

The proposed rule was published in the Federal Register as 91 FR 63870, covering pages 63870-64103.

2026-12-07 Deadline

Public comments must be received by the SEC on or before this date.

Suggested considerations

• Compliance teams may wish to determine whether client or fund crypto assets are currently held through arrangements that would constitute adviser or regulated-fund self-custody under the proposal, including arrangements involving service providers, private keys, wallets, or decentralized finance protocols.
• Firms should consider mapping proposed requirements for key management, joint authorization, asset segregation, safeguarding expertise, cybersecurity, incident response, annual review, internal control reporting, and client or investor account statements against existing custody, information-security, and operational-resilience controls.
• Advisers and regulated funds may wish to assess whether existing custodians, including state trust companies, could satisfy the proposed authorization, policy, audit, internal-control, and segregation conditions.
• Compliance teams should consider preparing comments for File No. S7-2026-35 by December 7, 2026, particularly on the proposed scope of self-custody, the qualified-custodian determination, treatment of airdropped crypto assets, decentralized finance activity, and the interaction with existing custody arrangements.
• Firms should assess potential changes to Form ADV, Form ADV-E, Form N-CEN, custody records, crypto-network records, audited financial statements, and accountant reports if the proposal is adopted.
• Investment advisers and regulated funds may wish to inventory tokenized private funds and tokenized regulated-fund shares in anticipation of the proposed additional Form ADV and Form N-CEN questions.
• Firms should distinguish proposal-stage planning from current legal obligations because the publication does not itself impose the proposed requirements and does not establish a final compliance date.

What changed

The proposal would add an adviser self-custody framework under proposed Advisers Act rule 223-1(b)(7), allowing an adviser to self-custody client crypto assets only in specified circumstances and subject to conditions addressing safeguarding expertise, documented safeguarding systems, key management, joint authorization, segregation, cybersecurity risk assessment, threat and vulnerability management, incident response and recovery, annual review, an internal control report, and client account statements.

Key dates

2026-09-14

EDGAR Release 26.3 was deployed. LIVE and TEST submissions became available for ANE Exception Notices, withdrawals, Form 1, and specified Form 1 variants; the revised EDGAR functionality and interfaces became operational.

2026-10-06

The final rule became effective, and incorporation by reference of the revised EDGAR Filer Manual Volume II, Version 78, into the Code of Federal Regulations was approved.

2026-12-31 Deadline

Last day on which ANE Exception Notices and withdrawals may be submitted by email.

2027-01-01 Deadline

ANE Exception Notices and withdrawals must be submitted electronically through the EDGAR online interface or by filer-constructed EDGAR submission; email submissions will no longer be accepted.

2027-03-01 Deadline

Last day on which Form 1 and specified Form 1 variants may be filed in paper.

2027-03-02 Deadline

Form 1 and specified variants must be submitted electronically through the EDGAR online interface or by filer-constructed EDGAR submission; paper filings will no longer be accepted.

Suggested considerations

• Compliance teams may wish to identify all ANE Exception Notices and withdrawals that could be submitted between January 1, 2027 and December 31, 2026, and establish procedures using the EDGAR online interface or filer-constructed submissions before the mandatory transition.
• Affected Form 1 filers may wish to obtain or validate EDGAR access, submit Form ID where required, and migrate filing procedures from paper to the EDGAR interface or filer-constructed submissions before March 2, 2027.
• Firms may wish to use the EDGAR test environment and, where applicable, the EDGAR Beta environment to test user access, filer-constructed submissions, validation, acknowledgments, and correction workflows.
• Filing teams may wish to update internal checklists and software templates for the corrected Forms 13F and 13F-CTR reference to Special Instruction 4.
• XBRL filers and filing agents may wish to replace references to the former Volume II XBRL instructions with the EDGAR XBRL Guide and confirm that current taxonomies and technical specifications are being used.
• Firms may wish to retain evidence of successful testing, accepted submissions, filing acknowledgments, and fallback procedures during the transition periods.
• Compliance teams may wish to review EDGAR access credentials, CIK status, delegated filing permissions, and responsible-person coverage for any filer converting from paper to electronic filing.

What changed

EDGAR Release 26.3 was deployed on September 14, 2026, and the SEC adopted the corresponding Filer Manual amendments as Version 78. Technical instructions for submitting XBRL documents were removed from Filer Manual Volume II and relocated to the EDGAR XBRL Guide. EDGAR submission templates for Forms 13F and 13F-CTR were corrected so that the cover-page reference points to Special Instruction 4 rather than Special Instruction 5.

Key dates

2020-12-23

FinCEN published the NPRM at 85 FR 83840 proposing additional reporting, recordkeeping, and identity-verification requirements for certain transactions involving unhosted or otherwise covered wallets.

2026-10-06

FinCEN withdrew the NPRM and stated that it would take no further action on that rulemaking.

Suggested considerations

• Compliance teams may wish to remove implementation workstreams, testing scenarios, and policy language that were created solely for the withdrawn NPRM's proposed $3,000 recordkeeping or $10,000 reporting thresholds.
• Firms should consider documenting that the NPRM was never effective and that its withdrawal does not eliminate existing obligations under the Bank Secrecy Act or applicable implementing regulations in 31 CFR parts 1010, 1020, and 1022.
• Banks and MSBs may wish to reassess whether current controls for transfers involving unhosted wallets remain risk-based and supported by documented AML risk assessments, rather than treating the withdrawn proposal's thresholds as mandatory rules.
• Crypto businesses should continue reviewing applicable customer-identification, customer-due-diligence, suspicious-activity-reporting, recordkeeping, transaction-monitoring, and OFAC sanctions requirements independently of this withdrawal.
• Regulatory-monitoring teams may wish to track whether FinCEN or Treasury develops a replacement digital-asset framework, particularly in light of the stated policy objective that digital-asset regulation be fit for purpose.

What changed

FinCEN withdrew the NPRM published at 85 FR 83840 and stated that it will take no further action on that rulemaking. The withdrawn proposal would have required banks and money services businesses to file reports when a transaction involving an unhosted or otherwise covered wallet exceeded $10,000, or multiple such transactions exceeded $10,000 in 24 hours. It also would have required records, counterparty information, and customer identity verification for covered transactions exceeding $3,000.

Key dates

2023-10-23

FinCEN published the proposed section 311 finding and special measure concerning international CVC mixing at 88 FR 72701.

2026-10-06

FinCEN's withdrawal of the finding and proposed rulemaking became effective upon Federal Register publication at 91 FR 63513.

Suggested considerations

• Compliance teams should discontinue implementation work that was undertaken solely for the withdrawn section 311 CVC-mixing proposal, including plans for the proposal-specific data fields, reporting workflows, and enhanced customer records.
• Firms should not interpret the withdrawal as authorization to process illicit mixer activity without controls; they should continue applying existing risk-based AML, sanctions, transaction-monitoring, escalation, and suspicious activity reporting procedures.
• Crypto exchanges and other covered institutions should review whether current transaction-monitoring scenarios appropriately identify mixer exposure and other indicators of money laundering or terrorist financing under existing requirements, without treating all privacy-preserving activity as inherently suspicious.
• Firms may wish to document the withdrawal in their regulatory inventory, rulemaking-impact assessments, and model or procedure change logs, while preserving controls that address independently applicable BSA or sanctions requirements.
• Compliance teams should monitor future FinCEN notices, section 311 actions, enforcement activity, and interpretive guidance because FinCEN expressly reserved the possibility of future measures concerning mixers.
• Legal and compliance functions should reassess any customer, product, or transaction restrictions adopted specifically in anticipation of the proposed rule and determine whether they remain justified by the firm's risk assessment, other legal requirements, or contractual obligations.

What changed

FinCEN withdrew the proposed rule published at 88 FR 72701 and the underlying section 311 finding concerning international CVC mixing. The proposed special measure one regime would have required covered financial institutions to report specified information for transactions they knew, suspected, or had reason to suspect involved international CVC mixing, including CVC type and amount, mixer and wallet information, transaction hashes, transaction dates, IP addresses, customer-identifying information, and a narrative description.

Key dates

2025-01-01

Beginning of the general period identified by the SEC during which the charged entities allegedly filed Forms ADV containing material misrepresentations; the publication does not specify an exact start date.

2026-08-27

The SEC announced the charges, disclosed the requested remedies, stated that the 38 ERA filings had been removed from its website, and referenced its related investor alert.

Suggested considerations

• Compliance teams may wish to perform a documented, line-by-line validation of Form ADV Part 1 and applicable Form ADV Part 2 disclosures, including business addresses, telephone numbers, websites, ownership, control persons, regulatory status, assets, private funds, clients, and service providers.
• Firms should consider retaining contemporaneous evidence supporting material Form ADV representations, such as lease or office records, corporate and ownership documents, fund records, audited financial statements, auditor engagement evidence, and records supporting reported assets and advisory activities.
• ERA and registered adviser compliance programs may wish to establish independent verification of counterparties' SEC registration or ERA status through the Investment Adviser Public Disclosure system and should avoid treating an SEC filing, certificate, or website badge as conclusive proof of legitimacy.
• Firms that market investment advice to individuals should consider reviewing whether their regulatory status, Form ADV disclosures, and marketing materials accurately describe whether they are registered, exempt reporting, or otherwise authorized to provide services to retail investors.
• Compliance teams may wish to investigate repeated or highly similar ownership structures, numerical disclosures, addresses, telephone numbers, websites, auditor names, or filing patterns across related advisers as potential indicators of coordinated fraudulent filings.
• Firms should consider escalating unanswered SEC requests for records and preserving relevant books, records, communications, websites, and filing-support materials, because the SEC expressly relied on alleged failures to substantiate Form ADV information.
• Private fund sponsors and allocators may wish to verify that purported fund audits were performed by identifiable independent public accounting firms with appropriate federal or state registration or licensing, rather than relying solely on statements in Form ADV.
• Financial-crime and onboarding teams may wish to incorporate the SEC's PAUSE list, investor alerts, foreign-jurisdiction indicators, website authentication checks, and independent corporate-registration checks into risk-based due diligence for purported U.S. advisers.

What changed

This publication announces enforcement complaints rather than a new rule or generally applicable filing requirement. The SEC alleges violations of Section 204(a) of the Investment Advisers Act of 1940, which governs adviser records and reports including Form ADV, and Section 207, which prohibits untrue statements or omissions in applications and reports filed under the Act. The SEC seeks permanent injunctions, conduct-based injunctions preventing the defendants from filing Forms ADV as exempt reporting advisers, and civil penalties.

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

2026-08-26

The CFTC proposed the amendment in 91 FR 55030, RIN 3038-AF79, and opened the public-comment period.

2026-09-25 Deadline

Public comments on the proposed rule must be received by the CFTC.

Suggested considerations

• SEF compliance teams should distinguish Required Transactions from Permitted Transactions under 17 CFR 37.9 and confirm that any planned platform changes preserve Order Book and RFQ functionality for Required Transactions.
• SEFs may wish to inventory Permitted Transaction products, execution protocols, customer usage, liquidity, pre-trade transparency, surveillance dependencies, and annual Order Book operating costs before deciding whether to retain, modify, or discontinue optional Order Book functionality.
• SEFs relying on CFTC No-Action Letter No. 25-24 should assess whether their current implementation remains consistent with the proposal and should monitor the eventual final rule rather than treating the NPRM as binding law.
• SEF applicants may wish to reassess platform design and launch costs because the proposal could remove the need to build an Order Book solely for Permitted Transactions.
• Swap dealers, major swap participants, and other active SEF users should assess whether removal of an optional Order Book could affect execution practices, liquidity access, pre-trade transparency, best-execution analysis, or internal trading procedures for Permitted Transactions.
• Interested firms should consider submitting comments to CFTC docket CFTC-2026-1882, including quantified technology, staffing, infrastructure, surveillance-integration, and market-impact data, by September 25, 2026.
• Compliance teams should continue applying CEA section 2(h)(8), 17 CFR 37.9, and applicable Part 43 reporting obligations unless and until a final rule changes them.

What changed

The proposed amendment would revise 17 CFR 37.3(a)(2) so that a SEF must, at a minimum, offer an Order Book as defined in 17 CFR 37.3(a)(3) for Required Transactions as defined in 17 CFR 37.9(a)(1). It would remove the obligation to offer an Order Book for Permitted Transactions, defined in 17 CFR 37.9(c)(1) as transactions that do not involve a swap subject to the CEA section 2(h)(8) trade-execution requirement. SEFs could continue offering Order Books for Permitted Transactions voluntarily and could use any execution method permitted under 17 CFR 37.9(c)(2).

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

2026-08-21

Request for Comment published in the Federal Register.

2026-10-20 Deadline

Comments are due, calculated as 60 days after Federal Register publication.

2026-10-05

Reported target date for CME Group and Silicon Data to list two compute or GPU-rental futures contracts, subject to regulatory review; this date is not established by the CFTC Request for Comment.

Suggested considerations

• Compliance teams may wish to determine whether the firm has relevant empirical data on compute prices, volumes, counterparties, supplier concentration, utilization, capacity commitments, or bilateral contract terms that could support a CFTC submission.
• Potential DCM and SEF applicants should consider mapping proposed contract specifications and settlement methodologies against CEA section 5(d), Core Principles 2, 3, 4, 5, 9, and 11, 17 CFR 38.150-38.160, 38.200-38.201, 38.250-38.258, 38.500, and 38.603, and the guidance in 17 CFR part 38 appendices B and C.
• Firms developing or contributing data to a compute index should consider documenting data provenance, publication practices, governance, auditability, contributor concentration, observation-window controls, fallback mechanisms, and safeguards against manipulation by capacity providers.
• FCMs, introducing brokers, and other intermediaries may wish to assess whether existing BSA/AML, KYC, onboarding, suitability, disclosure, and market-conduct controls address the risks identified for compute derivatives, including opaque bilateral markets and geopolitically sensitive supply.
• Market participants may wish to submit comments by the applicable deadline, clearly referencing RIN 3038-AF77 and the Request for Comment on the Listing of Compute Derivatives Contracts, while avoiding unnecessary personal or confidential business information because submissions will be publicly posted.
• Firms tracking product development should consider monitoring any subsequent DCM self-certification or Commission-approval filing, as the consultation itself does not authorize trading or postpone a proposed listing.

What changed

No final rule, approval, prohibition, or new compliance obligation was introduced. The CFTC is requesting comment on compute cash-market size, liquidity, transparency, supplier concentration, fungibility, benchmark methodology, deliverable supply, manipulation risks, surveillance feasibility, customer protection, heightened BSA/AML and KYC issues, retail protections, and the design and risks of perpetual compute futures.

Key dates

2026-08-21

Proposal published in the Federal Register for public comment.

2026-10-05 Deadline

Written comments are due 45 days after Federal Register publication.

Suggested considerations

• Firms should assess each pool’s investor eligibility against the natural-person and non-natural-person requirements in proposed Regulation 4.13(a)(4), including the distinctions between qualified eligible persons and accredited investors.
• RIAs should review offering documents, subscription procedures, investor representations, and transfer controls to support the required reasonable belief at investment or conversion that all participants satisfy the applicable eligibility criteria.
• Compliance teams may wish to confirm that each relevant pool’s interests qualify for a Securities Act exemption and that U.S. marketing practices comply with the proposed restriction, including the Rule 506(c) exception.
• Eligible advisers should map Form PF obligations and determine whether existing SEC filings would satisfy the proposed condition that Form PF be filed where required.
• Firms should prepare to file or update electronic exemption notices with the NFA and maintain the proposed Regulation 4.13 annual affirmation, recordkeeping, disclosure, and statutory-disqualification representations.
• Managers operating both registered and exempt pools should assess the proposed Regulation 4.13(e)(2) communications and redemption-right requirements and identify whether any existing participants would require notice before a pool is operated as exempt.
• Small-pool operators should model eligibility using the proposed $800,000 aggregate threshold while continuing to monitor the 15-participant-per-pool limit and unchanged contribution exclusions.
• Managers relying on Staff Letter 25-50 should preserve evidence of current compliance and evaluate transition implications because the CFTC preliminarily proposes to supersede that relief if the rule is finalized.

What changed

Proposed Regulation 4.13(a)(4) would exempt an SEC-registered investment adviser from CPO registration for qualifying pools if the pool interests are exempt from Securities Act registration and are not publicly marketed in the United States, except that the marketing restriction would not apply to pools offered under SEC Rule 506(c) of Regulation D.

Key dates

2025-09-10

Tricolor and affiliates filed for Chapter 7 bankruptcy and moved toward liquidation.

2025-12-17

The U.S. Attorney’s Office for the Southern District of New York announced criminal charges against Tricolor executives in connection with the alleged fraud.

2026-08-18

The SEC announced the civil enforcement action against Daniel Chu, Jerome Kollar, and Ameryn Seibold in the U.S. District Court for the Southern District of New York.

Suggested considerations

• Firms should consider performing a targeted review of whether the same receivable, loan, vehicle, inventory item, or other asset can be pledged across multiple warehouse facilities, securitizations, lenders, or managed accounts, including through affiliates and special-purpose vehicles.
• Compliance teams may wish to test collateral eligibility and borrowing-base reporting back to source-level records, payment histories, lien and ownership data, servicing systems, and independent third-party evidence rather than relying solely on management certifications.
• Securitization sponsors, underwriters, and investors should consider reviewing controls for detecting loans that are delinquent, charged off, non-paying, fictitious, materially impaired, or otherwise ineligible but reported as current or eligible.
• Firms should consider reconciling loan-level collateral tapes across all funding channels and establishing exception escalation, independent sign-off, segregation of duties, and documented remediation for duplicate identifiers or inconsistent pledging data.
• Finance and compliance functions may wish to assess whether offering documents, investor presentations, lender certificates, and management meetings accurately describe liquidity constraints, funding needs, collateral encumbrances, and portfolio performance.
• Boards and senior-management committees should consider reviewing governance over collateral operations, securitization disclosures, liquidity reporting, related-party or affiliate financing, and controls over executive certifications.
• Investment managers and lenders may wish to incorporate independent collateral verification, borrowing-base audit rights, data-access rights, concentration and duplication analytics, and covenant triggers into new and renewed transactions.
• Firms with relevant exposure should consider preserving records, communications, collateral tapes, system audit trails, certifications, underwriting files, and exception reports in light of parallel SEC and criminal proceedings.

What changed

The publication does not introduce a new rule, threshold, filing requirement, or compliance deadline. It announces an enforcement complaint under the antifraud provisions of the Securities Act of 1933 and Securities Exchange Act of 1934, including alleged control-person liability against Chu and aiding-and-abetting liability against all three defendants. The SEC seeks injunctions, disgorgement with prejudgment interest, civil penalties, and officer-and-director bars against Chu and Kollar.

Key dates

2026-08-18

The SEC published the Chairman’s statement and proposed Regulation Crypto Assets, including the proposed startup exemption, fundraising exemption, and investment-contract safe harbor.

2026-03-17

The SEC issued its interpretation concerning the application of the federal securities laws to certain crypto assets and transactions, which the Chairman identifies as a basis for the proposed framework.

Suggested considerations

• Compliance teams may wish to treat the package as a proposal rather than a currently usable exemption and continue applying the existing Securities Act, Exchange Act, and applicable state-law analysis until final rules become effective.
• Potential issuers should consider mapping planned token offerings against the proposed $5 million/four-year and $75 million/12-month limits, including aggregation, timing, resale, and interaction with other registration exemptions once the proposing release is reviewed in full.
• Issuers considering the fundraising exemption should consider preparing systems for principles-based crypto disclosures, financial-condition information, audited financial statements at the applicable thresholds, and ongoing reporting.
• Legal and compliance functions may wish to assess whether existing investment-contract documentation contains essential managerial promises and whether operational evidence could support the proposed certification required for the safe harbor.
• Crypto trading venues and intermediaries should consider inventorying assets currently treated as securities or investment contracts and evaluating how a future safe-harbor determination could affect onboarding, trading permissions, disclosures, custody, surveillance, and state-law analysis.
• Firms may wish to monitor the Federal Register publication, the SEC comment period, any revisions to the proposal, and the status of the CLARITY Act, which the Chairman described as necessary for durable market-structure rules.
• Compliance teams may wish to review independent commentary emphasizing that the proposal is a major policy shift toward tailored token fundraising but that the practical scope remains uncertain until the detailed conditions, audit thresholds, eligibility criteria, and final text are settled.

What changed

The proposed rules would establish two exemptions from Securities Act of 1933 registration for qualifying crypto-asset investment contracts. The startup exemption would permit offerings of up to $5 million during a four-year period. The fundraising exemption would permit offerings of up to $75 million during each 12-month period, subject to principles-based crypto-asset disclosures, financial-condition disclosures, financial statements, ongoing reporting, and audited financial statements at specified capital-raising thresholds; the publication does not state those audit thresholds.

Key dates

2026-03-17

The SEC issued its earlier interpretation clarifying how federal securities laws apply to certain crypto assets and transactions involving crypto assets.

2026-08-18

The SEC announced the proposed Regulation Crypto Assets framework and opened the process for public comment, subject to publication of the proposing release in the Federal Register.

Suggested considerations

• Compliance teams may wish to map planned and existing token offerings against the proposed $5 million four-year and $75 million 12-month thresholds, including aggregation across related issuers, affiliates, projects and offering periods once the proposing release is reviewed.
• Issuers should consider documenting which exemption they would use, the relevant measurement period, investor eligibility and transfer restrictions, and controls intended to prevent exceeding the applicable offering cap.
• Firms should consider preparing draft principles-based narrative disclosures and, for the $75 million exemption, assessing financial-statement readiness and the systems needed for ongoing SEC reporting.
• Project sponsors may wish to inventory all essential managerial efforts represented or promised to investors and establish evidence, governance approvals and public communications supporting any future safe-harbor position based on completion or permanent cessation of those efforts.
• Exchanges, broker-dealers and trading platforms should consider assessing how the proposed safe harbor and state-law preemption could affect asset classification, listing reviews, customer disclosures, surveillance, custody and secondary-market controls.
• Industry participants may wish to review the full proposing release and consider submitting comments within 60 days after its publication in the Federal Register; the specific deadline should not be assumed until the Federal Register publication date is confirmed.
• Firms should continue treating the proposal as non-final and should not represent that an exemption, safe harbor or state-law preemption is currently available.

What changed

The proposed framework would add two exemptions from Securities Act of 1933 registration requirements for qualifying investment contracts involving crypto assets. The first would allow aggregate offerings of up to $5 million during a four-year period on a one-time basis; the second would allow offerings of up to $75 million during each 12-month period. Issuers relying on either exemption would need to make specified principles-based narrative disclosures available to investors.

Key dates

2026-08-18

CFTC announced publication of a Notice of Proposed Rulemaking concerning amendments to Part 4 CPO and CTA registration requirements.

Suggested considerations

• Compliance teams may wish to obtain and review the full Federal Register proposal, including the precise sophisticated-investor criteria, pool-level conditions, adviser eligibility requirements, proposed small-pool capital threshold, effective date, and transition provisions.
• Firms should consider mapping each existing and prospective pool against the proposed CPO exemption conditions and each advisory mandate against the proposed CTA exemption conditions, without treating the proposal as currently available relief.
• SEC-registered advisers may wish to compare the proposed exemption with their current CFTC registration status, CFTC Regulation 4.13 or 4.14 filings, Rule 4.7 reliance, and any applicable CFTC staff no-action relief.
• Small-pool operators should consider recalculating eligibility using the proposed inflation-adjusted capital-contribution threshold once the precise amount is published and assessing whether existing offering, subscription, and compliance controls would continue to demonstrate compliance.
• Affected firms may wish to assess whether to submit comments within 45 days after Federal Register publication, particularly on investor definitions, treatment of derivatives and swaps, aggregation rules, recordkeeping, reporting, and coordination with SEC adviser requirements.
• Firms relying on existing exemptions or no-action letters should continue meeting their current conditions and filing obligations unless and until a final rule or separate relief changes them.
• Legal and regulatory inventories may be updated to cross-reference CFTC Regulations 4.5, 4.7, 4.13, and 4.14, the Commodity Exchange Act, and the Investment Advisers Act of 1940.

What changed

The CFTC issued a Notice of Proposed Rulemaking proposing amendments to Part 4. The proposal would add a CPO registration exemption for certain investment advisers registered with the SEC in connection with commodity pools whose participants are limited to specified sophisticated investors and that satisfy additional conditions set out in the proposal. It would add a related CTA registration exemption. It would also increase the capital-contribution threshold applicable to the existing small commodity pool exemption under CFTC Regulation 4.13 to account for inflation.

Key dates

2026-08-14

The SEC announced the enforcement action and filed the complaint in the U.S. District Court for the Southern District of New York.

2020-12-01

Approximate beginning of the conduct period alleged by the SEC.

2025-06-30

Approximate end of the conduct period alleged by the SEC.

Suggested considerations

• Firms should consider reconciling every investor-facing statement about upfront fees, markups, commissions, carried interest, advisory fees, transaction spreads, and total acquisition cost against actual fund and affiliate-level economics.
• Compliance teams may wish to map all principal transactions and related-party transfers between advisers, sponsors, general partners, feeder funds, and portfolio-acquisition vehicles, with documented conflict reviews and valuation support.
• Firms should consider testing whether each person soliciting private-fund interests is properly registered or otherwise operating within an applicable broker-dealer exemption, and whether compensation arrangements create broker-dealer registration or supervision concerns.
• Compliance teams may wish to review cold-calling scripts, call recordings, lead-generation practices, sales-agent training, and escalation controls for high-pressure claims, guaranteed or implied returns, scarcity statements, and misleading descriptions of pre-IPO access.
• Firms should consider verifying offering exemptions, investor eligibility, registration status, subscription documentation, and disclosure delivery for each private fund and distribution channel.
• Compliance teams may wish to perform targeted surveillance of retail and retiree sales, including cancellation or cooling-off requests, unusual concentration, complaints about undisclosed fees, and differences between quoted and realized investor charges.
• Firms should consider preserving communications, transaction records, fee calculations, investor files, sales-agent compensation data, and valuation materials in anticipation of regulatory inquiries or investor claims.

What changed

This is a civil enforcement action, not a new rule or generally applicable safe harbor. The SEC alleges violations of the antifraud, securities-registration, and broker-dealer-registration provisions of the Securities Act of 1933, the Securities Exchange Act of 1934, and the Investment Advisers Act of 1940, together with control-person liability and aiding-and-abetting violations by Spaventa.

Key dates

2026-08-14

The CFPB announced and implemented the cessation of discretionary publication of complaint narratives and associated visualizations in the Consumer Complaint Database; previously published narratives remain subject to proactive FOIA Reading Room disclosure.

Suggested considerations

• Compliance teams may wish to continue treating CFPB complaints as supervisory and potential enforcement inputs, notwithstanding the removal of narratives from the public database.
• Firms should consider maintaining controls that support complete, accurate, and timely responses to CFPB complaints, including documented investigation, escalation, remediation, and quality-assurance procedures.
• Complaint-management owners may wish to monitor whether the removal of public narratives affects internal trend analysis and should preserve their own historical complaint records and supporting evidence.
• Legal and regulatory affairs teams should consider reviewing previously published complaint narratives concerning the firm in the CFPB FOIA Reading Room and assessing whether existing disclosure, litigation, reputation, and remediation processes remain appropriate.
• Firms should consider retaining evidence supporting complaint responses because complaint information may continue to be shared with prudential regulators, the FTC, and federal or state agencies, and may remain accessible through FOIA.
• Management may wish to avoid interpreting the change as a basis for reducing complaint-governance staffing, monitoring, root-cause analysis, or board and senior-management reporting.

What changed

The CFPB will no longer publish consumer-submitted complaint narratives or related data visualizations in the Consumer Complaint Database. The Bureau characterizes publication of these materials as discretionary rather than statutorily required and states that the materials are unverified, potentially misleading, and not necessarily evidence of legal violations.