On December 30, 2025, the OCC proposed rules affirming national banks’ authority over mortgage escrow accounts and preempting state interest-on-escrow laws.

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[1] OCC, Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the Office of the Comptroller ...

FDIC and OCC Issue NPR to Eliminate ‘Reputation Risk’ from Supervisory Programs ...

On March 20, 2026, the White House released a national AI policy framework, pursuant to President Trump’s executive order dated December 11, 2025, which urges Congress to adopt a federally unified, ...

On October 24, the Federal Reserve Board released two proposals to update its supervisory stress testing framework, seeking comment on enhanced model transparency, disclosure processes, and proposed ...

FDIC Releases Additional Information on Initiative to Modify the IDI Plan Rule and Publishes New Materials on Failed Bank Marketing and Sale Process ...

On April 7, Treasury Secretary Scott Bessent and Federal Reserve Chair Jerome Powell held an urgent meeting with major bank CEOs to address cybersecurity threats from Anthropic’s AI model Claude ...

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In a Decision that Turned on Market Definition, the U.S. District Court for the District of Columbia Ruled that the FTC Failed to Prove that Meta Illegally Maintained a Monopoly ...

For more information on these and other developments, we encourage you to reach out to your regular Sullivan & Cromwell contact. Highlights In this issue, we discuss key developments in Q3 2025, ...

On September 29, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an immediately effective interim final rule (referred to as the “Affiliates Rule”) which amends ...