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PH FedACTion: Financial Regulatory Updates

Daily Financial Regulation Update -- Wednesday, December 10, 2025

December 10, 2025

Edited by Lawrence D. Kaplan, Jason Shafer and Kris Knabe

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Federal Agencies

Office of the Comptroller of the Currency

OCC Confirms Bank Authority to Engage in Riskless Principal Crypto-Asset Transactions

December 9, 2025

The Office of the Comptroller of the Currency (OCC) confirmed permissible bank activities related to riskless principal transactions in crypto assets.

 

Comptroller Gould Discusses De Novo Charters

December 8, 2025

Comptroller of the Currency Jonathan V. Gould discussed the agency’s activities to reinvigorate the chartering of new banks following the 2008 financial crisis in remarks at the Blockchain Association Policy Summit.

 

Securities and Exchange Commission

Investor Bulletin: Health Savings Accounts

December 9, 2025

The Securities and Exchange Commission’s (SEC) Office of Investor Education and Assistance issued an investor bulletin on health savings accounts (HSAs).

 

Commodity Futures Trading Commission

CFTC to Accelerate Publication of Backlogged COT Data

December 9, 2025

The Commodity Futures Trading Commission (CFTC) is accelerating the publication of Commitments of Traders (COT) reports that were interrupted during the lapse in federal appropriation. 

 

FINRA

FINRA Publishes 2026 Regulatory Oversight Report 

December 9, 2025

FINRA published the 2026 FINRA Regulatory Oversight Report.

 

Federal Housing Finance Agency

Federal Housing Finance Agency Announces Deemed-Issuance Ratio for 2026

December 9, 2025

The Federal Housing Finance Agency announced the deemed-issuance ratio for the 2026 calendar year in accordance with Internal Revenue Service (IRS) guidelines on the trading of the Uniform Mortgage-Backed Security (UMBS).

 

State Agencies

Conference of State Bank Supervisors

CSBS and MISMO Announce MCD Tech Sprint Problem Statements

December 9, 2025

The Conference of State Bank Supervisors (CSBS) and MISMO, the real estate finance industry’s standards organization, announced the problem statements that will guide the next phase of the Mortgage Compliance Dataset (MCD) Tech Sprint.

 

International

Bank of England

Mortgage Lenders and Administrators Statistics — Q3 2025

December 9, 2025

The Bank of England released the Mortgage Lenders and Administrators Statistics for Q3 2025.

 

2025 CCP Stress Test: Results Report

December 9, 2025

The Bank of England released the results of the 2025 CCP Stress Test.

 

Financial Conduct Authority

FCA Simplifies Insurance Rules and Plans Further Reviews of Requirements

December 9, 2025

The Financial Conduct Authority (FCA) confirmed changes to simplify its rules and lower costs for insurers while maintaining appropriate levels of protection for smaller commercial customers.

 

Consultation Paper: ‘Enhancing fund liquidity risk management’

December 9, 2025

The FCA issued a consultation paper titled “Enhancing fund liquidity risk management.”

 

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

Practice Areas

Bank Regulatory

Financial Services

Global Finance


For More Information

Image: Kris Knabe
Kris Knabe

Of Counsel, Litigation Department