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.
The U.S. banking regulatory landscape was bustling during June, reflecting the current economic and geopolitical landscapes. On Capitol Hill, legislation was advanced to help integrate digital assets into the financial system, with movement toward the regulation of payment stablecoin and the establishment of a digital market structure. The U.S. banking agencies have worked together to take a stronger stance on mitigating the risk of check and payment fraud, while also independently working on the development of a more tailored regulatory system. Read about these topics—and more—in the following summary of activities in the U.S. banking regulatory world.
On Capitol Hill
The end of May wrapped up with the introduction of the Digital Asset Market Clarity Act of 2025 (CLARITY Act) in the U.S. House of Representatives. This bill aims to provide a comprehensive regulatory structure for digital assets by more clearly delineating the responsibilities of the SEC and the Commodity Futures Trading Commission (CFTC) in the digital landscape.
On June 17, the U.S. Senate passed the GENIUS Act by a vote of 68 to 30. The largely bipartisan bill sets out a regulatory framework that permits the issuance of payment stablecoins and allows for their integration into the U.S. financial system. For more details, see our FORsights™ article, “GENIUS Act – Ushering in a Transformative Era of Digital Assets.”
On June 20, President Donald Trump signed joint resolution S.J.Res.13 into law, thereby nullifying the Office of the Comptroller of the Currency (OCC) revised bank merger rule. In the joint resolution, Congress expressed its disapproval of the OCC’s revised rule that eliminated automatic approvals under an expedited review procedure and ceased the acceptance of streamlined application forms.
Joint Agency Statements
SEC & CFTC Vote to Extend Compliance Date
On June 11, the SEC and the CFTC voted to extend the period of compliance for the Form PF amendments. The compliance date is now scheduled for October 1, giving more than a six-month extension from the original date of March 12. Form PF is a confidential reporting form for specific SEC-registered investment advisers, including those advisers who are also registered with the CFTC as commodity trading advisers. This deadline postponement is intended to allow more time for the programming and testing of these amendments by filers.
FDIC, Federal Reserve Board (FRB), & OCC Tackle Check & Payments Fraud
On June 16, the FDIC, the FRB, and the OCC released a joint request for information seeking public commentary on potential ways to mitigate the risks of check and payments fraud. The agencies issued this statement to assist in the development of a more comprehensive set of supervisory actions to combat payments fraud so no single agency has to tackle the problem of fraud independently. Public input is requested by September 14, 2025 on the following five areas: external collaboration; consumer, business, and industry education; regulation and supervision to mitigate payments fraud; payments fraud data collection and information sharing; and Federal Reserve Banks’ operator tools and services to reduce payments fraud.
FRB, FDIC, & OCC Revise the Enhanced Supplemental Leverage Ratio for GSIBs
On June 25 and 26, the agencies approved a joint notice of proposed rulemaking to modify the enhanced supplementary leverage ratio (eSLR) for global systemically important bank (GSIB) holding companies and their insured depository institution (IDI) subsidiaries. Under the existing rule, each U.S. GSIB must maintain an eSLR of 5% and each IDI subsidiary must maintain an eSLR of 6%. The proposed revision would modify the eSLR requirements for U.S. GSIBs and IDIs to 3% plus half of the institution’s GSIB surcharge. The stated purpose of the change is to reduce the binding nature of the leverage ratio, which could lessen impediments for institutions to engage in the intermediation of U.S. Treasury securities. For more information, see our FORsights article, “U.S. Banking Agencies Revise the Enhanced Supplementary Leverage Ratio.”
Agencies Issue Exemption to Customer Identification Program (CIP) Requirements
On June 27, the agencies, consisting of the OCC, FDIC, and National Credit Union Administration, with concurrence of the Financial Crimes Enforcement Network (FinCEN), announced an exemption from the requirements of the CIP Rule implemented by Section 326 of the USA PATRIOT Act. Under the existing rule, a bank or credit union is required to obtain the taxpayer identification number (TIN) information from its customers for all accounts at account opening. Under the new rule, if a bank or credit union otherwise complies with the provisions of the CIP rule, it is permitted to use an alternative collection method to obtain TIN information from a third party rather than the customer if the institution has written procedures that:
- Enable the bank to obtain TIN information prior to opening an account;
- Are based on the bank’s assessment of the relevant risks; and
- Are risk-based for the purpose of verifying the identity of each customer to the extent reasonable and practicable, enabling the bank to form a reasonable belief that it knows the true identity of each customer.
For most traditional banks and credit unions, the operational impact is anticipated to be nominal, but for digital-first or tech-enabled institutions, especially those with embedded finance or fintech partners, this update provides useful operational flexibility.
Federal Reserve Board
Federal Reserve Vice Chair for Supervision Weighs in on Ratings Framework
On June 6, recently appointed Vice Chair for Supervision Michelle Bowman gave a speech regarding supervision and regulation at Georgetown University’s McDonough School of Business. The four main principles she addressed surrounded (1) enhancing supervision to more effectively and efficiently meet the Fed’s safety and soundness goals; (2) reviewing and reforming the capital framework to help ensure it is appropriately designed and calibrated; (3) reviewing regulations and information collections to help ensure that this framework remains viable; and (4) considering approaches to help ensure the applications process is transparent, predictable, and fair.
The vice chair emphasized the future tailoring of the regulatory framework to separate standards between large and small financial institutions. In addition, Bowman highlighted the “subjectivity of examiner ratings in the CAMELS framework and the impending need for improvement of the system to appropriately reflect the material financial risk of each financial institution.” She spoke on this topic again in a June 23 speech, which focused more on Treasury market functioning and the federal banking agencies’ need to revisit the leverage ratio.
FOMC Holds Interest Rates Steady
The Federal Open Market Committee (FOMC) released a statement holding the federal funds rate at 4.25 to 4.5%. This decision to hold rates steady was accompanied by an acknowledgement of low unemployment rates, solid labor market conditions, and overall optimism about the economic outlook. In addition, the committee recognized the volatility of the market and international events collectively, promising preparedness to adjust rates as needed in the future.
Stress Test Results
The Federal Reserve’s annual bank stress test was released on June 27. The stress test evaluates a bank’s capital capacity to assist households and businesses in a severe recession. Under a hypothetical stress scenario, a bank’s estimated losses, net revenue, and capital levels are calculated to test resilience to commercial and residential real estate and corporate debt markets as measured by a hypothetical decline in common equity tier 1 capital under the stress scenario. Twenty-two banks were tested this year. The stress test showed that in a hypothetical recession, the aggregate decline in common equity tier 1 capital is estimated to be 1.8 percentage points. This aggregate decline is smaller than the declines measured in recent years.
Examination Programs Component Revision
On June 23, the FRB announced that reputational risk will no longer be a component of its examination program. The removal and update of materials to reflect this change has begun, and FRB examiners are expected to implement this change across all board-supervised banks. Reputational risk materials are now replaced with detailed discussions of financial risk and improving risk management practices. This action joins the OCC and FDIC, which had previously removed reputational risk from their examination programs.
Office of the Comptroller of the Currency
From the Comptroller
Acting Comptroller of the Currency Rodney Hood began June with an address to the U.S. Chamber of Commerce Capital Markets Summit. His speech centered on four strategies to foster continued growth of the banking system while simultaneously supporting the rise of technology in the financial space: (1) accelerating bank-fintech partnerships, (2) expanding responsible engagement with digital assets, (3) advancing financial inclusion as an economic imperative, and (4) modernizing regulation to unleash growth.
On June 9, Hood released a letter defending the OCC’s preemption rule, addressing state regulators’ claims that it was unlawful. Preemption refers to the legal principle that federal law supersedes state laws if ever they conflict regarding the regulation of national banks. State regulators claim that the “preemption rule gives national banks an upper hand over smaller, state-chartered banks.” In his letter, the acting comptroller stated that the OCC’s preemption rule is lawful, supports competition, and is a “cornerstone of the dual banking system.”
The OCC Releases Q1 2025 Bank Trading Revenue Report
On June 23, the OCC released its quarterly report on bank trading from all insured U.S. national and state commercial banks. There were 1,213 OCC-supervised insured financial institutions generating aggregate trading revenue of $15 billion, 2.7% less than the previous quarter and 1.9% less than a year ago. JPMorgan Chase, Citibank, Goldman Sachs, and Bank of America represented 87.1% of the total banking notional amounts and almost 75% of industry net current credit exposure (NCCE). Overall, NCCE decreased 7.9% from the previous quarter.
Federal Deposit Insurance Corporation
The FDIC Issues List of Banks Examined for CRA Compliance
On June 5, the FDIC released its periodic statement presenting the results of the FDIC-regulated banks evaluated for the Community Reinvestment Act (CRA) compliance. In total, 66 institutions were assessed during the period. For a list of banks examined for CRA compliance, visit the FDIC website.
Consumer Financial Protection Bureau
CFPB Acting Enforcement Director Resigns
The Consumer Financial Protection Bureau’s (CFPB) Acting Enforcement Director Cara Petersen resigned1 from her position on June 10. Petersen was the second head of enforcement for the agency this year, as her predecessor Eric Halperin resigned in February. No replacement for her position has been announced.
CFPB Extends the Compliance Dates for Small Business Lending Under the ECOA (Regulation B)
Section 1071, a subset of sweeping changes implemented by the Dodd-Frank Wall Street Reform and Consumer Protection Act, amended the Equal Credit Opportunity Act (ECOA) to include provisions requiring covered financial institutions to compile, maintain, and submit certain protected demographic and credit application data for women-owned, minority-owned, and small businesses as an annual filing to the CFPB. Prudentially, §1071’s aim is to facilitate enforcement of fair lending laws and identify community development credit needs for women-owned, minority-owned, and small businesses. However, ongoing litigation in several jurisdictions has stayed the rule's compliance deadlines. As a result, on June 18, 2025, the CFPB announced amendments to the compliance dates initially set forth in its 2023 small business lending rule and amended by a 2024 interim final rule. The new rule extends the compliance date for covered institutions by approximately one year and requires them to begin collecting data as follows:
| Covered financial institution compliance tier | Original compliance date in the 2023 final rule | Revised compliance date in the 2024 interim final rule | New compliance date | New first filing deadline |
|---|---|---|---|---|
| Tier 1 | October 1, 2024 | July 18, 2025 | July 1, 2026 | June 1, 2027 |
| Tier 2 | April 1, 2025 | January 16, 2026 | January 1, 2027 | June 1, 2028 |
| Tier 3 | January 1, 2026 | October 18, 2026 | October 1, 2027 | June 1, 2028 |
The definition of each compliance tier remains unchanged, though the interim rule permits covered financial institutions to use originations spanning 2022 to 2023, 2023 to 2024, or 2024 to 2025, respectively, to determine which tier they fall into.
The CFPB is seeking comments on the interim final rule. All comments are due on or before July 18, 2025.
Securities and Exchange Commission
The SEC Removes 14 Proposed Rules
On June 12, the SEC withdrew 14 proposed rules issued between March 2022 and November 2023. The withdrawal statement highlighted a broad shift in the agency’s regulatory goals and priorities. The SEC stated that any future rulemaking in these areas will be accompanied by new proposals and issuances compliant with the Administrative Procedure Act. The following proposed rules have been removed:
- Substantial Implementation, Duplication, and Resubmission of Shareholder Proposals
- Conflicts of Interest Associated with the Use of Predictive Data Analytics by Broker-Dealers and Investment Advisers
- Safeguarding Advisory Client Assets
- Cybersecurity Risk Management for Investment Advisers, Registered Investment Companies, and Business Development Companies
- Enhanced Disclosures by Certain Investment Advisers and Investment Companies About Environmental, Social, and Governance Investment Practices
- Outsourcing by Investment Advisers
- Position Reporting of Large Security-Based Swap Positions
- Volume-Based Exchange Transaction Pricing for NMS Stocks
- Regulation Best Execution
- Order Competition Rule
- Regulation Systems Compliance and Integrity
- Cybersecurity Risk Management Rule for Broker-Dealers, Clearing Agencies, Major Security-Based Swap Participants, the Municipal Securities Rulemaking Board, National Securities Associations, National Securities Exchanges, Security-Based Swap Data Repositories, Security-Based Swap Dealers, and Transfer Agents
- Amendments Regarding the Definition of “Exchange” and Alternative Trading Systems (ATSs) That Trade U.S. Treasury and Agency Securities, National Market System (NMS) Stocks, and Other Securities
- Amendments to the National Market System Plan Governing the Consolidated Audit Trail To Enhance Data Security
SEC Will Resume Processing Registration Applications for Swiss Banks
The SEC announced on June 10 that it would begin processing registration applications for Swiss financial institutions wanting to register as investment advisers in the United States. This ends a six-year regulatory stalemate between the two countries’ financial sectors, following a long-standing disagreement with Swiss banking authorities. With more discussions to follow, the SEC is looking to have access to Swiss advisers’ books and records and conduct on-site inspections in Switzerland. Swiss wealth managers are now looking forward to obtaining American clients.
SEC Extends Deadline for Rule 15c3-3 Compliance
On June 25, the SEC announced it will extend its compliance date for amendments to Rule 15c3-3, also known as the broker-dealer customer protection rule. The amendments state that certain broker-dealers must increase the frequency of required reserve computations from weekly to daily. The agency has extended the deadline to June 30, 2026, a full six months past the initial compliance date of December 31, 2025. The extension is crucial to allow more time for any necessary systems or operational changes needed to implement the daily computation requirement.
Commodity Futures Trading Commission
Pham Speaks at Piper Sandler Global Exchange & Trading Conference
The CFTC announced its 2025 Spring Unified Regulatory Agenda at the Piper Sandler Global Exchange and Trading Conference on June 5. Acting Chair Caroline Pham spoke on the need to provide regulatory clarity, decrease unnecessary spending, and foster a better space for markets. Pham gave the following rulemaking initiatives as the road map to help achieve those goals:
- Improving the swap execution facility (SEF) “Made Available to Trade” (MAT) process for swaps
- Expanding access to markets for insured depository institutions by broadening the scope of products excluded from the swap dealer de minimis threshold calculation
- Expanding access to markets by no longer requiring associated person registration for personnel of introducing brokers that only refer swaps to a wholly owned affiliate de minimis dealer
- Codifying foreign exchange product interpretation that window foreign exchange (FX) forwards and package spot FX transactions are not FX swaps
- Codifying no-action relief from both the pre-trade mid-market mark disclosure requirement and certain documentation requirements for cleared swaps and prime brokerage transactions for swap dealers
- Codifying no-action relief from the clearing requirement for legacy swaps resulting from multilateral portfolio compression exercises
- Codifying no-action relief from ownership and control reporting under Parts 17, 18, and 20 of CFTC regulations
- Codifying no-action relief for designated contract markets (DCMs) and derivative clearing organizations (DCOs) from duplicative reporting of fully collateralized binary options to swap data repositories (SDRs) under Parts 43 and 45 of CFTC regulations
- Sunsetting duplicative and burdensome Part 20 large trader reporting obligations for physical commodity swaps, as required under Regulation 20.9
- Eliminating the burdensome and costly cotton-on-call reporting requirements and related CFTC Cotton-on-Call Report
Pham emphasized this agenda was compliant and pursuant to Trump’s executive order. She then concluded her speech with a call to action of greater cooperation between the CFTC and the public, as well as with other regulatory organizations.
Quintenz Is Lead Nominee for CFTC Commissioner
Former CFTC Commissioner2 Brian Quintenz is Trump’s nominee to lead the organization after having served as commissioner during Trump’s previous term in office. In his prepared remarks for his Senate hearing, Quintenz noted a need for a regulatory framework for crypto assets and digital currency. Following former President Joe Biden’s inauguration into office, Quintenz went to Andreessen Horowitz, a venture-capital firm, where he now leads the firm’s crypto unit. If confirmed as commissioner, the nominee has stated plans for blockchain and crypto technology. Quintenz’s Senate hearing was June 10.
Financial Accounting Standards Board
Interim Reporting – Narrow Scope Improvements (Topic 270)
In its June 18 board meeting, FASB made tentative decisions with respect to amendments to Interim Reporting (Topic 270): Narrow-Scope Improvements. The amendments are designed to provide clarity on Topic 270 by providing clearer guidance on when interim reporting rules apply, align more closely with SEC Regulation S-X, and introduce a comprehensive list of required interim disclosures. The amendments would be effective for interim reporting beginning after December 15, 2027 for public business entities and after December 15, 2028 for entities other than public business entities. The board asked staff to draft a final update for final vote.
Accounting for Government Grants
In a June 25 FASB board meeting, FASB affirmed its decision to update Government Grants (Topic 832): Accounting for Government Grants by Business Entities in a manner that would leverage certain requirements under International Accounting Standards 20. The decision was made in a narrow 4-3 vote.3 FASB instructed staff to develop a final update for vote by written ballot.
On the International Front
Basel Committee on Banking Supervision Adjusts Frameworks
In 2023, the Basel Committee on Banking Supervision (BCBS) issued a proposal for a disclosure framework for climate-related financial risks, which would have integrated measures into Pillar 3 of the Basel Accords and required the member jurisdictions to implement bank-specific disclosure requirements for climate-related financial risks. On June 13, the BCBS published its final framework, a voluntary framework for the disclosure of climate-related financial risks, which drops the earlier requirement to disclose facilitated emissions and leaves it to the jurisdictions to decide whether to implement climate disclosure requirements.4 The election would be completely voluntary; however, for jurisdictions that choose to implement climate disclosure requirements, the BCBS has indicated it will not monitor adherence to its framework. While it is unclear which jurisdictions will move forward with disclosure requirements, the U.S. banking agencies stated they will not move forward with climate-disclosure requirements for U.S. banks.
Earlier in the month, the BCBS issued a technical amendment to its Basel III endgame standards.5 The amendment is meant to address inconsistencies in the treatment of rental income under the standardized approach for operational risk. In addition, the pronouncement includes an FAQ as an interpretive supplement to the issues addressed, i.e., the standardized approaches to operational risk and credit risk. Comments on the proposed technical amendment are invited until July 25, 2025.
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.
- 1“Top enforcement official resigns from CFPB amid internal turmoil,” cnn.com, June 11, 2025.
- 2“CFTC nominee Quintenz seeks to leverage crypto expertise,” bankingdive.com, June 10, 2025.
- 3“New U.S. accounting rule to establish how companies must record government grants,” wsj.com, June 27, 2025.
- 4“A framework for the voluntary disclosure of climate-related financial risks,” bis.org, June 13, 2025.
- 5“Various technical amendments and frequently asked questions,” bis.org, June 10, 2025.