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Agencies Release 2026 Threshold Adjustments For Various Consumer Lending Rules
The Dodd-Frank Act requires the banking agencies to annually adjust dollar amount thresholds in certain consumer lending regulations. The annual adjustments are based on annual percentage increases in the Consumer Price Index (“CPI”) from year-to-year.
FinCEN Issues Enforcement Action Against Cryptocurrency Exchange Platform
On December 9, 2025, FinCEN announced a consent order against Paxful, Inc., and Paxful USA, Inc. (collectively, “Paxful”) for BSA violations (the “Order”).
FDIC and OCC Repeal Interagency Guidance on Leveraged Lending
The OCC and the FDIC (collectively “Agencies”) have previously issued guidance addressing how financial institutions should manage risks arising from exposures to leveraged lending. In March 2013, the Agencies issued guidance titled “Interagency Guidance on Leveraged Lending” (the “2013 Guidance”).
NCUA Announces Deregulation Project and Eight Proposed Regulatory Changes
Over a two-week period in December 2025, the NCUA announced a new initiative to review the agency’s regulations and two rounds of proposed regulatory changes. On December 10, 2025, the NCUA announced four proposed regulatory changes and then it announced another four on December 23, 2025.
OCC Issues Guidance Clarifying that National Banks May Engage in Riskless Principal Transactions Involving Crypto-assets
On December 9, 2025, the OCC issued interpretative letter #1188 (“IL 1188”) which confirms that conducting riskless principal crypto-asset transactions is an activity that is permissible for national banks. As a bit of background, in a riskless principal transaction an intermediary (often a bank) purchases an asset from a counterparty (“Initial Counterparty”) for immediate resale to a second counterparty (the “Purchaser”).
CFPB Adjusts HMDA Exemption Asset-size Threshold
On January 7, 2026, the CFPB published a final rule amending Regulation C (which implements the Home Mortgage Disclosure Act (HMDA) asset thresholds) to establish a new asset-sized exemption threshold for depository institutions for 2026.
Table of Contents
CONSUMER FINANCE
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Agencies Release 2026 Threshold Adjustments For Various Consumer Lending Rules
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OCC Issues Pair of Proposed Rules on Preemption of State Interest-on-escrow Laws
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Freddie Mac Issues New AI Guidelines
BANKING OPERATIONS & FINTECH
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FinCEN Issues Enforcement Action Against Cryptocurrency Exchange Platform
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OCC Publishes Preliminary Report on Debanking Findings
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California District Court Finds Cayman Islands Accountholders Lack Standing in FDIC Suit
COMMERCIAL LENDING
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FDIC and OCC Repeal Interagency Guidance on Leveraged Lending
CREDIT UNIONS
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NCUA Announces Deregulation Project and Eight Proposed Regulatory Changes
CORPORATE GOVERNANCE
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OCC Issues Guidance Clarifying that National Banks May Engage in Riskless Principal Transactions Involving Crypto-assets
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Regulators Issue No-Action Statements on Certain Regulation O Lending
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FDIC Issues Proposed Rule on Applications for Stablecoin Issuers under the GENIUS Act
CRA/HMDA CORNER
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CFPB Adjusts HMDA Exemption Asset-size Threshold
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Agencies Update Community Reinvestment Act’s Asset Thresholds
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OCC Proposed Simplified Strategic Plan Process for Community Banks
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