Forvis Mazars has summarized this month’s activity in the U.S. banking regulatory landscape to help you keep up to speed on this quickly evolving regulatory environment.
November saw the government shutdown come to an end as Congress passed its latest funding bill. The U.S. banking agencies remained active during the month, releasing multiple proposed rule makings, updates to policies, and guidance. Among them are several sweeping updates that appear poised to reshape the supervisory and regulatory landscape for institutions. Explore this and more in the following summary of activities in the U.S. banking regulatory ecosystem.
Navigating the Evolving U.S. Banking Regulatory Landscape: Key Highlights From November 2025
The U.S. banking regulatory environment saw a few developments in November 2025, spanning legislative, supervisory, and international fronts. Here are the quick hits:
- Joint Agency Statements
- The U.S. banking agencies approved a final rule to modify the enhanced supplementary leverage ratio (eSLR) for global systemically important bank holding companies (GSIBs).
- The U.S. banking agencies proposed revisions to the community bank leverage ratio (CBLR) framework.
- Federal Reserve Updates
- The Federal Reserve Board (FRB) extended the comment period for its stress testing proposal.
- The FRB announced significant changes to its bank supervision procedures.
- The agency finalized updates to its Large Financial Institution (LFI) supervisory rating framework.
- OCC Initiatives
- The Office of the Comptroller of Currency (OCC) tailored Bank Secrecy Act (BSA)/anti-money laundering (AML) examination procedures for community banks.
- The OCC clarified its position on holding crypto assets as principal and paying crypto asset network fees.
- The OCC updated its Servicemembers Civil Relief Act (SCRA) examination procedures.
- FDIC Updates
- The FDIC finalized its rule modifying threshold adjustments and indexing to reflect inflation across several regulations.
- The FDIC finalized amendments to signage and advertising requirements.
- The FDIC announced modifications to institution compliance examination schedules and introduced a new compliance midpoint risk analysis for certain institutions.
- CFPB Agenda
- The Consumer Financial Protection Bureau (CFPB) proposed updates to the Equal Credit Opportunity Act (ECOA) and additional revisions to Section 1071.
- SEC Developments
- The SEC Division of Examinations announced its 2026 priorities.
- The SEC clarified its position on Rule 14a-8 requests for the upcoming proxy season.
- FASB Updates
- FASB approved new projects for its technical agenda targeting digital assets and accounting for equity method investments.
- FASB issued an update to Accounting Standards Codification (ASC) 326.
Joint Agency Statements
The U.S. Banking Agencies Finalize Modifications to the Enhanced Supplementary Leverage Ratio Standards for GSIBs
On November 25, 2025, the U.S. banking agencies approved publication of their final rule to modify the eSLR for GSIBs bank holding companies and their insured depository institution (IDI) subsidiaries. The rule was largely approved as proposed in its notice of proposed rulemaking (NPR), dated July 10, 2025. For more information on the proposal, see our FORsights™ alert, “U.S. Banking Agencies Revise the Enhanced Supplementary Leverage Ratio.”
The final rule does include one important change. The NPR proposed modifying the SLR standard for covered IDIs from the current “well capitalized” threshold under the prompt corrective action framework at 6% to 3% plus an eSLR buffer of 50% of the parent GSIB’s surcharge calculation. However, the final rule caps the IDI eSLR buffer at 1%. The agencies noted that this cap is aimed at maintaining the eSLR requirement as a backstop to the risk-based capital requirements since the IDI, unlike its GSIB parent, is not subject to the GSIB risk-based capital surcharge or the stress capital buffer requirement.
In addition, the final rule provides that the eSLR buffer applicable to a national bank or federal savings association that is a subsidiary of a U.S. top-tier bank holding company with total consolidated assets of more than $700 billion (or assets under custody of more than $10 trillion) that does not have a parent GSIB method 1 surcharge is 1%. As a result, in some cases, a national bank that is not a GSIB subsidiary could have an eSLR requirement higher than the eSLR requirement of a national bank that is a GSIB subsidiary.
The final rule is effective on April 1, 2026, but GSIBs and covered institutions may voluntarily adopt the eSLR standards as of January 1, 2026.
The U.S. Banking Agencies Propose Revisions to the Community Bank Leverage Ratio Framework
On November 25, 2025, the U.S. banking agencies advanced a proposal to revise the CBLR Framework. The following revisions are proposed:
- Lower Calibration of the CBLR Requirement: The agencies are proposing to lower the CBLR requirement from 9% to 8%.
- Extension of the Grace Period: Community banks that fail to meet the qualifying criteria after opting into the CBLR framework would have four reporting periods to meet the qualifying criteria again, provided they maintain a leverage ratio above 7% and have not used the grace period for more than eight of the prior 20 quarters.
- Removal of Temporary CARES Act Provisions: The agencies propose removing the provisions under the CBLR framework that provided temporary relief for qualifying community banking organizations during the COVID-19 outbreak.
The agencies also posed several questions related to other potential changes or adjustments that should be considered. Public comments are requested for 60 days after publication in the Federal Register. For more information, see our FORsights alert, “US Agencies Propose Updates to Community Bank Leverage Ratio.”
Federal Reserve Board
FRB Extends the Comment Period on Its Proposal to Improve Stress Test Model & Scenario Transparency & Accountability
On November 21, 2025, the FRB announced it will extend the comment period on its proposal to improve stress test model and scenario transparency and accountability from January 22, 2026 under the initial request for comment, to February 21, 2026. The move was made in an effort to allow interested parties more time to analyze the issues and prepare their comments.
Comments on the FRB’s proposed 2026 Supervisory Stress Test scenarios are still due on December 1, 2025.
FRB Announces Enhancements to Its Bank Supervision Procedures
On November 18, 2025, the FRB released a Statement of Supervisory Operating Principles outlining a significant shift in its supervisory principles. The stated goal of these changes is to strengthen supervision by prioritizing earlier, timely, and proportionate action to address the most important risks to the safety and soundness of banks and to the U.S. financial system. At a high level, the following topics are addressed within the statement:
- Focus on material financial risks and reasoned judgment;
- Prioritization of supervisory attention;
- Reliance on primary supervisors and resource allocation by complexity;
- Joint work with state supervisors;
- Termination of matters requiring attention (MRA)/matters requiring immediate attention (MRIA) and post-remediation monitoring;
- Horizontal reviews limited;
- Liquidity assumptions and the Federal Home Loan Bank (FHLB)/Discount Window; and
- Supervisory ratings and MRA and MRIA issuance.
For financial institutions, the statement signals a significant shift away from supervisory practices that have placed emphasis on procedural tasks. Instead, expect the FRB to concentrate on financial risks that may materially impact safety and soundness. In addition, the statement provides financial institutions’ internal audit functions with more weight in validating the remediation of MRA or MRIAs, increasing the importance of a well-developed internal audit program. For more information, see our FORsights article, “FRB Announces Supervisory Operating Principles: What Financial Institutions Need to Know.”
FRB Finalizes Changes to Its Large Bank Holding Company Supervisory Rating Framework
On November 5, 2025, the FRB finalized changes to its supervisory rating framework for large bank holding companies. Stemming from the agency’s request for comment on a proposal to revise its LFI supervisory rating framework on July 10, 2025, the framework was finalized largely without change. As such, under the final framework, an organization with at least two “Broadly Meets Expectations” or “Conditionally Meets Expectations” component ratings and no more than one “Deficient-1” component rating will be considered “Well Managed.” In addition, the final framework removes the presumption that one or more “Deficient-1” component ratings automatically will result in informal or formal enforcement action. Instead, the nature and circumstances of any findings will be considered before the determination of formal or informal enforcement action is made. Notably, the criteria for determining if a firm’s component rating is “Broadly Meets Expectations,” “Conditionally Meets Expectations,” “Deficient-1,” or “Deficient-2” remained unchanged.
The final framework also updates certain references, including removing a reference to reputational risk. The aim of the revisions is to better align the supervisory rating framework with the strength of bank holding companies and the banking system as a whole. Furthermore, the changes seek to better align the LFI rating system with the supervisory rating systems.
Office of the Comptroller of the Currency
OCC Eases Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Guidance for Community Banks
On November 25, 2025, the OCC announced supervisory and regulatory actions to reduce the burden for community banks. In a series of bulletins, the agency clarified its approach to BSA/AML examination procedures applicable to community banks and reduced community bank data collection requirements moving forward. Specifically, the OCC announced plans to tailor the application of certain BSA/AML examination procedures for all community banks based on the generally low levels of money laundering and terrorist financing risk posed by community banks. These bulletins include:
- Bulletin 2025-37: BSA/AML: Community Bank Minimum BSA/AML Examination Procedures
- Bulletin 2025-38: BSA/AML: Discontinuation of AML Risk System Data Collection
In addition, the OCC published a Request for Information, Bulletin 2025-39: Bank Activities: Request for Information on Community Banks’ Engagement with Core Service Providers and Other Essential Third-Party Service Providers, soliciting comments on the key challenges and barriers faced by community banks in engaging with core service providers and other essential third-party service providers. Comments must be received within 60 days of publication in the Federal Register.
For more information and an overview of each bulletin, see our FORsights article, “OCC Eases Regulatory Burden for Community Banks.”
OCC Offers Clarification for Holding Crypto Assets as Principal & Paying Crypto Asset Network Fees
On November 18, 2025, the OCC published Interpretive Letter 1186, which permits national banks to hold native crypto assets on the balance sheet as principal and pay blockchain network fees, referred to as “gas fees.” The OCC specified that this authority extends to instances when such holdings are reasonably necessary to support otherwise permissible banking activities. Furthermore, the OCC ties this permissibility to a bank’s ability to manage the legal, operational, and risk-control issues associated with holding and using crypto assets.
For banks, this letter signals regulatory acceptance of certain crypto asset holdings, while emphasizing that such activity must be supported by robust governance, compliance, custody, liquidity, and risk management frameworks.
OCC Updates Its Servicemembers Civil Relief Act (SCRA) Handbook
On November 13, 2025, the OCC issued Bulletin 2025-36, which details updates to the SCRA booklet of the Comptroller’s Handbook. Several changes were introduced to the regulator’s examination procedures, including but not limited to:
- Risk-based supervision approach to assessing compliance with the SCRA;
- Eliminates the prior OCC policy requirement to conduct an SCRA examination that included transaction testing at least once every three supervisory cycles;
- Clarifies language on servicemember verification and distribution of excess payments;
- Removes references to reputation risk; and
- Added operational risk considerations related to third-party risk management.
Federal Deposit Insurance Corporation
FDIC Finalizes Rule Modifying Regulatory Threshold Adjustments & Indexing to Reflect Inflation
On November 25, 2025, the FDIC adopted a final rule to amend certain regulatory thresholds to index the following key audit and reporting thresholds to reflect changes in historical inflation:
- 12 CFR Part 303: Filing Procedures;
- 12 CFR Part 335: Securities of State Nonmember Banks and Savings Associations;
- 12 CFR Part 340: Restrictions on Sale of Assets of a Failed Institution by the Federal Deposit Insurance Corporation;
- 12 CFR Part 347: International Banking;
- 12 CFR Part 363: Annual Independent Audits and Reporting Requirements; and
- 12 CFR Part 380: Orderly Liquidation Authority.
The rule was largely approved as proposed on July 15, 2025. For more information, see our FORsights alert, “FDIC Considers New Policy for Updated Regulatory Thresholds.” The final rule includes modifications or clarifications to provisions within the proposal in the following areas:
| Topic/Regulation | Proposed Provision(s) | Final Rule(s) |
|---|---|---|
| Indexing Methodology for Future Threshold Adjustments | “Under the proposal, the FDIC generally would announce threshold adjustments pursuant to the indexing methodology by publishing a final rule in the Federal Register…The adjusted thresholds would be effective on April 1 of the year during which the adjustment occurs.” | The final rule provides that such adjustments will take effect on October 1. |
| Part 363 Applicability | N/A | If an IDI is likely to no longer be subject to a part 363 requirement as a result of a threshold adjustment that is scheduled to occur during the IDI’s current fiscal year, the final rule permits the IDI’s appropriate federal banking agency to exercise discretion to provide exemptive relief to the IDI. |
The new thresholds are effective as of January 1, 2026; however, to provide immediate burden relief, an IDI does not have to comply with certain part 363 requirements in effect as of December 31, 2025, if the IDI will not be subject to those part 363 requirements under the updated thresholds. For a deeper dive into the final rule, see our FORsights article, “FDIC Finalizes Policy for Updated Regulatory Thresholds.”
FDIC Finalizes Amendments to Official Signs & Advertising Requirements
On November 25, 2025, the FDIC published a notice extending the compliance date from March 1, 2026 to January 1, 2027 for the requirements under 12 CFR 328.5 to display the FDIC official digital sign related to an IDI’s digital deposit-taking channels and requirements related to IDI’s automated teller machines and like devices under 12 CFR 328.4.
Consistent with the FDIC’s NPR issued on August 21, 2025, the rule looks to reduce burden and address potential consumer confusion with respect to signage requirements for digital deposit-taking channels, automated teller machines (ATMs), and similar devices. For more information, see the excerpt “FDIC Proposes Amendments to Official Signs & Advertising Requirements” within our FORsights article, “Monthly Banking Regulatory Review – August 2025.”
FDIC Updates Its Consumer Compliance Examination Schedule
On November 7, 2025, the FDIC published Financial Institution Letter (FIL) 52-2025, which announced modifications to the Consumer Compliance Examination Manual that significantly update the consumer compliance examination cadence, adjusting the frequency of consumer compliance examinations and Community Reinvestment Act (CRA) evaluations for FDIC-supervised institutions under the $3 billion assets threshold.
In addition, the FDIC has introduced a new compliance midpoint risk analysis for certain institutions. This revision aims to better align supervisory resources with the evolving risk profiles of institutions and reduce unnecessary burden on lower-risk institutions. For more on the updates, see our FORsights alert, “FDIC Updates their Consumer Compliance Examination Schedule.”
Consumer Financial Protection Bureau
CFPB Proposes Additional Revisions to §1071
On November 13, 2025, the CFPB proposed revisions to certain provisions of its small business lending rule, implementing changes to the Equal Credit Opportunity Act made by §1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The proposed changes aim to streamline the rule, reduce complexity for lenders, and improve data quality to better align with the spirit of §1071. Key changes include:
- Streamlined data requirements. The CFPB proposes narrowing certain mandatory data fields to reduce reporting burdens on lenders.
- Clarified definitions and applicability thresholds. Updates to covered credit and excluded transactions, small business, borrower, and loan category definitions, among others, are intended to ensure consistency in how institutions classify small business credit applications.
- Extended compliance timelines. The proposal contemplates additional time, extended through January 1, 2028, for institutions to implement systems and processes to comply with the rule.
- Enhanced privacy safeguards. Modifications emphasize stronger protections around sensitive demographic and financial information collected.
Together, these proposed revisions reflect the CFPB’s effort to balance regulatory transparency with operational feasibility, ensuring that lenders meet their compliance obligations without undue administrative burden. Public comments are requested through December 15, 2025.
CFPB Proposes ECOA Updates
On November 13, 2025, the CFPB proposed amendments to Regulation B under the ECOA that would significantly narrow the scope of liability and reshape compliance expectations. The publication proposes eliminating references to the “effects test,” clarifying that the ECOA does not authorize disparate-impact claims. This marks a departure from prior reliance on legislative history and aligns with recent executive orders.
The proposal also revises discouragement provisions. Specifically, it clarifies that violations occur when creditors make oral or written statements of intent to discriminate, rather than when consumers perceive negative impressions. In addition, creditor communications exhibiting encouraging statements directed at one group will not be considered discouragement of others outside of the intended audience.
Finally, the proposal imposes new requirements on special purpose credit programs (SPCPs), particularly for for-profit institutions, mandating more rigorous written plans and compliance safeguards to ensure these programs meet statutory standards without undermining ECOA protections.
Collectively, these changes aim to reduce legal exposure tied to neutral policies and procedures, provide clearer boundaries for credit communications, and heighten oversight of SPCPs. Public comments are requested through December 15, 2025.
Securities & Exchange Commission
SEC Division of Examinations Announces 2026 Priorities
On November 17, 2025, the SEC’s Division of Examinations released its 2026 Examination Priorities. The examination priorities are developed in coordination and consultation with the other divisions and offices throughout the SEC, taking into consideration the prior year’s examination findings, market events, and information gathered through participation in conferences and conversations with stakeholders and other regulators. Furthermore, they reflect practices, products, and services that the Division believes present potentially heightened risks to investors or integrity to the U.S. capital markets.
For 2026, the Division of Examinations set a risk-focused agenda emphasizing fiduciary conduct and compliance program effectiveness for advisers and funds; broker-dealer financial responsibility, trading practices, and retail sales, including Regulation BI; clearing agency resilience; and oversight of self-regulatory organizations and other market intermediaries. Heightened attention is expected in several areas, including but not limited to cybersecurity, operational resilience, identity theft safeguards, emerging fintech and artificial intelligence controls, and anti-money laundering. Exams will probe governance, vendor controls, and liquidity and valuation practices.
SEC Announces It Will Not Review Most No-Action Requests for Rule 14a-8 for Next Proxy Season
On November 17, 2025, the Division of Corporation Finance of the SEC announced that it will not respond to no-action requests for the exclusion of Rule 14a-8 shareholder proposals, other than no-action requests to exclude a proposal under Rule 14a-8(i)(1) for the current proxy season, dated October 1, 2025 to September 30, 2026. The announcement was made citing “current resource and timing considerations following the lengthy government shutdown and the large volume of registration statements and other filings requiring prompt staff attention,” as well as “the extensive body of guidance” from the commission and its staff on Rule 14a‑8 proposals.
Financial Accounting Standards Board
FASB Approves New Projects for Its Technical Agenda
On November 19, 2025, FASB met to discuss the accounting for transfers of crypto assets. As a result of the discussion, FASB added a project to its technical agenda related to the accounting for crypto asset transfers that will include:
- Expanding the scope of Subtopic 350-60, Intangibles—Goodwill and Other—Crypto Assets, to address wrapped tokens and receipt tokens; and
- Clarifying the derecognition guidance for crypto transfer arrangements to assess whether the control of a crypto asset has been transferred.
With the launch of this project, in conjunction with the project on the classification of certain digital assets as cash equivalents, FASB removed the Digital Assets project from its research agenda. For more information, see our FORsights article, “Accounting for Stablecoins: Navigating Uncertainty Within US GAAP.”
On November 12, 2025, FASB met to discuss stakeholder feedback on the 2025 Invitation to Comment on the equity method of accounting and renewable energy partnership and determine whether to add a project to its technical agenda. At the meeting’s end, FASB approved a tentative decision to launch a new project with the following scope:
- Accounting for equity method investments in partnerships and similar entities where the investor maintains presumptive levels of influence but is unable to significantly influence the operating and financial policies of the investee; and
- Clarify how equity method investors in non-real-estate entities should determine equity in earnings for investees with complex allocation structures.
Currently, no new guidance has been issued; however, we are monitoring future developments.
FASB Releases ASU 2025-08: Update to ASC 326
On November 12, 2025, FASB released an update to ASC 326, Financial Instruments – Credit Losses, to address concerns regarding complexity and lack of comparability in the accounting for purchased loans under the current credit loss standard (Topic 326). The Accounting Standards Update (ASU) removes the previous distinction in accounting between purchased credit-deteriorated (PCD) assets and non-PCD assets by applying the “gross-up” accounting method, formerly used only for PCD assets, to most acquired loans. These loans will now be designated as “purchased seasoned loans” (PSLs). This change eliminates the Day-1 credit loss expense on PSLs, which the industry considered a “double-count” of expected losses on acquired performing loans, by instead recognizing expected credit losses at acquisition without immediate impact to earnings.
The new guidance is effective for annual reporting periods beginning after December 15, 2026, including interim periods within those fiscal years. In addition, early adoption is permitted in an interim or annual reporting period when financial statements have not yet been issued or made available for issuance. For more information, see our FORsights article, “FASB Releases ASU 2025-08: Update to ASC 326.”
Additional Updates
| Agency | Date | Topic | Description |
|---|---|---|---|
| OCC | 11/3/25 | OCC Releases CRA Performance Evaluations | The OCC released its results of national banks and federal savings associations evaluated for CRA compliance. |
| FDIC | 11/3/25 | FDIC Issues List of Banks Examined for CRA Compliance | The FDIC released its results of state non-member banks evaluated for CRA compliance. |
| SEC | 11/3/25 | Notice of Designation of a Longer Period for Commission Action on Pending Proposed Rule Changes and Proceedings to Determine Whether to Approve or Disapprove | The SEC’s Division of Trading and Markets extended the statutory review period for several self-regulatory organization and clearing agency proposed rule changes to allow additional time to consider the filings and their issues, with new action dates listed within the release. |
| FFIEC | 11/13/25 | Federal Bank Regulatory Agencies Release Small Business, Small Farm, and Community Development Lending Data | As part of its responsibility under the CRA, the federal bank regulatory agencies released data on small business, small farm, and community development lending during 2024. |
| FDIC | 11/24/25 | FDIC Quarterly Banking Profile – Q3 2025 | The FDIC released its latest quarterly banking profile, which shows bright spots within the industry as IDIs reported a return on assets ratio of 1.27% and aggregate net income of $79.3 billion, up approximately $9.4 billion from the prior quarter, strong net interest income growth, and a reduction in provision expense for the third quarter of 2025. |
| FDIC | 11/25/25 | Notice of Designated Reserve Ratio for 2026 | The FDIC Board of Directors announced the Designated Reserve Ratio for the Deposit Insurance Fund will remain at 2% for 2026. |
From Forvis Mazars
In the heavily regulated banking industry, leaders face more challenges than ever, from managing shareholder and regulatory expectations to pursuing digital innovation. Forvis Mazars can help your financial institution tackle issues inherent to the industry, including market growth, internal control threats, industry consolidation, and compliance. We have the skills and experience in financial services that you can trust. Combine our focus on Unmatched Client Experience® with the resources of a global firm, and you will find that Forvis Mazars is the trusted adviser your institution needs. Serving you is our passion and privilege.
If you have any questions or need assistance, please reach out to a professional at Forvis Mazars.