PH FedACTion: Financial Regulatory Updates
Daily Financial Regulation Update -- Friday, December 19, 2025
December 19, 2025
Edited by Lawrence D. Kaplan, Jason Shafer and Kris Knabe
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Major Developments
Securities and Exchange Commission
Statement on the Custody of Crypto-Asset Securities by Broker-Dealers
December 17, 2025
The Securities and Exchange Commission’s (SEC) Division of Trading and Markets released a statement on the custody of crypto-asset securities by broker-dealers.
FAQs on Crypto-Asset Activities and Distributed Ledger Technology
December 17, 2025
The SEC’s Division of Trading and Markets has released frequently asked questions relating to crypto-asset activities and distributed ledger technology.
Federal Agencies
U.S. Department of the Treasury
Treasury International Capital Data for October
December 18, 2025
The U.S. Department of the Treasury released Treasury International Capital (TIC) data for October 2025. The next release, which will report on data for November 2025, is scheduled for Jan. 15, 2026.
Federal Reserve Board
Fed Publishes First Staff Manual for Supervision of Largest Banks
December 18, 2025
The Federal Reserve Board published the first of several staff manuals for the supervision of the largest and most complex banks.
Fed Releases December 2025 Senior Credit Officer Opinion Survey
December 18, 2025
The Federal Reserve Board released the Senior Credit Officer Opinion survey for December 2025.
Federal Deposit Insurance Corporation
Office of the Comptroller of the Currency
OCC and FDIC Clarify Supervisory Expectations on Insider Lending Compliance and Reporting Requirements
December 18, 2025
The Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) issued a statement to clarify supervisory expectations for OCC and FDIC supervised institutions’ compliance with insider lending restrictions and related reporting requirements with respect to certain types of related interests.
Office of the Comptroller of the Currency
OCC Issues Bulletin on Rescissions
December 18, 2025
The OCC has reviewed its issuances to identify outdated documents for rescission and released a bulletin rescinding 55 outdated or replaced issuances published between 1983 and 2023, as well as 21 transmittal bulletins issued between 2003 and 2023.
Commodity Futures Trading Commission
CFTC Approves Final Rule to Revise Swap Dealer Business Conduct and Swap Documentation Requirements
December 18, 2025
The Commodity Futures Trading Commission (CFTC) announced it has approved a final rule that codifies existing staff no-action positions for some of the CFTC’s business conduct and documentation requirements applicable to swap dealers and major swap participants.
CFTC Staff Seeks Public Comment on Direct Clearing by Retail Participants
December 18, 2025
CFTC staff issued a request for comment to better inform the staff’s understanding of the issues related to derivatives clearing organizations that provide direct clearing services to retail traders.
National Credit Union Administration
NCUA Board Approves Budget, Receives Update on Share Insurance Fund
December 18, 2025
The National Credit Union Administration Board held its seventh open meeting of 2025 and received a briefing on the agency’s operating budgets for 2026-27. The board was also briefed on the performance of the National Credit Union Share Insurance Fund for Q3 2025.
International
European Banking Authority
EBA Publishes Update on Equivalence Monitoring Activities
December 18, 2025
The European Banking Authority (EBA) has updated its confidential report on equivalence monitoring activities and submitted it to European Parliament, the European Council, the European Commission and the other European supervisory authorities.
European Regulators Sign MoU in Support of Nonbank PSPs’ Access to Payment Systems
December 18, 2025
The EBA, the European Central Bank (ECB), national central banks and national supervisory authorities across the European Economic Area have signed a memorandum of understanding (MoU) to strengthen cooperation and information sharing in support of nonbank payment service providers’ (PSPs) access to central bank-operated payment systems.
Bank of England
Bank Rate Reduced to 3.75%
December 18, 2025
The Bank of England’s Monetary Policy Committee voted by a majority of 5–4 to reduce the Bank Rate by 0.25 percentage points, to 3.75%. Four members voted to maintain the Bank Rate at 4%.
Agents’ Summary of Business Conditions — December 2025
December 18, 2025
The Bank of England released the agent’s summary of business conditions for December 2025.
Artificial Intelligence Consortium Minutes — October 2025
December 18, 2025
The Bank of England released the minutes of the Artificial Intelligence Consortium in October 2025.
Decision Maker Panel Survey — Q4 2025
December 18, 2025
The Bank of England released the Decision Maker Panel survey results for Q4 2025.
Administration Changes
Vacancies
Appointments
U.S. Department of the Treasury – Scott Bessent (effective January 27, 2025)
Federal Reserve Board – Jerome H. Powell (effective May 23, 2022)
- Vice Chair Phillip N. Jefferson (sworn in September 13, 2023)
- Vice Chair for Supervision Michelle W. Bowman (sworn in June 9, 2025)
- Governor Michael Barr (sworn in July 19, 2022)
- Governor Christopher J. Waller (sworn in December 18, 2020)
- Governor Lisa D. Cook (sworn in September 13, 2022 – SCOTUS hearing on purported termination to be held in January 2026)
- Stephen Miran (sworn in September 16, 2025)
Federal Reserve Bank of New York – John C. Williams (effective June 18, 2018)
Federal Reserve Bank of Boston – Susan M. Collins (effective July 1, 2022)
Federal Deposit Insurance Corporation – Travis Hill (Acting Chairman effective January 20, 2025, nominated to be Chair September 30, 2025)
- Vice Chairman Vacant
- Director Vacant
- Director Jonathan Gould (Comptroller of the Currency)
- Director Russel Vought (Director of Consumer Financial Protection Bureau)
Office of the Comptroller of the Currency – Jonathan Gould (effective July 15, 2025)
Securities and Exchange Commission – Paul Atkins (effective April 9, 2025)
Commodity Futures Trading Commission – Caroline D. Pham (Acting Chairman effective January 20, 2025)
Consumer Financial Protection Bureau – Russel Vought (Acting Director effective February 10, 2025)
National Credit Union Administration – Kyle Hauptman (Chairman effective January 20, 2025)
Small Business Administration – Kelly Loeffler (effective February 19, 2025)
U.S. Department of Housing and Urban Development – Scott Turner (effective February 5, 2025)
Federal Housing Finance Agency – William Pulte (effective March 13, 2025)
U.S. Department of Education – Linda McMahon (effective March 3, 2025)
Financial Crimes Enforcement Network – Andrea Gacki (effective July 13, 2023)
PH Client Alerts
Click here to read more from our Coronavirus series.
Legislation/Legislative Updates
Click here to view the full text of the Coronavirus Aid, Relief and Economic Security Act (the “CARES Act”), enacted March 27, 2020.
Click here to view the full text of the Paycheck Protection Program Increase Act of 2020, enacted April 24, 2020.
Click here to view the full text of the Paycheck Protection Program Flexibility Act of 2020, enacted June 5, 2020.
Click here to view the full text of theConsolidated Appropriations Act, 2021, enacted December 27, 2020.
Click here to view the full text of the American Rescue Plan of 2021, enacted March 11, 2021.
Click here to view the full text of the PPP Extension Act of 2021, enacted March 30, 2021.
Click here to view a running list of proposed legislation from the Senate Committee on Banking, Housing and Urban Affairs, Senate Committee on Small Business and Entrepreneurship, House Committee on Financial Services and House Committee on Small Business
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