On October 7, 2025, the OCC and the FDIC issued two separate notices of proposed rulemaking designed to refocus supervisory practices and enhance clarity around enforcement standards. Both proposals reflect a broader regulatory shift toward prioritizing material financial risks and ensuring consistency in supervisory expectations.

Oct 7
Oct 7 OCC Eases Regulatory Burden for Community Banks

Adam Witmer

Regulatory Update

On October 6, 2025, the OCC announced guidance to banks and proposed rulemakings to reduce regulatory burden for community banks. According to the OCC, these actions build upon its continued efforts to tailor its regulatory and supervisory frameworks to minimize burden for its regulated institutions and promote economic growth.

Oct 6
Oct 6 FinCEN Requests Comments on the Renewal of Information Sharing Requirements

Adam Witmer

Regulatory Update, BSA

On September 30, 2025, FinCEN issued a notice and request for comments on the proposed renewal, without change, of existing information collection requirements found in BSA regulations concerning information sharing between government agencies and financial institutions.

Oct 2
Oct 2 Agencies Issue Reminder to Institutions on Lending When the NFIP Is Unavailable

Adam Witmer

Flood, Regulatory Update

On October 1, 2025, the federal agencies issued a reminder to lenders that they may continue to make loans that are subject to the federal flood insurance statutes when the National Flood Insurance Program is not available.

Oct 2
Oct 2 CFPB Finalizes 1071 Final Rule Compliance Extension

Adam Witmer

Regulation B, Regulatory Update

On October 2, 2025, the CFPB issued a final rule to finalize its June 18 interim final rule amending Regulation B to extend the compliance dates of the small business lending rule and to make other date-related conforming adjustments. This final rule becomes effective on December 1, 2025.

Oct 1
Oct 1 FinCEN Postpones Residential Real Estate Reporting Rule

Adam Witmer

BSA, Regulatory Update

On September 30, 2025, FinCEN announced that it will postpone reporting requirements of the Anti-Money Laundering Regulations for Residential Real Estate Transfers Rule (RRE Rule) until March 1, 2026. FinCEN stated that this is to provide industry with more time to comply while still adequately protecting the U.S. financial system from money laundering, terrorist financing, and other serious illicit finance threats.

Sep 29
Sep 29 NCUA Removes Reputational Risk from Supervisory Processes

Adam Witmer

Regulatory Update

On September 25, 2025, the NCUA announced that it had stopped the use of reputation risk and equivalent concepts in the examination and supervisory process. These updates come after White House Executive Order 14331, which requires federal banking regulators to stop using "reputational risk" or similar ideas that could lead to politically motivated or unlawful debanking.

Sep 24
Sep 24 Treasury Targets Financial Network Supporting Iran’s Military

Adam Witmer

Regulatory Update, BSA

On September 16, 2025, the OFAC designated a pair of Iranian financial facilitators and more than a dozen Hong Kong- and United Arab Emirates (UAE)-based individuals and entities. These entities were sanctioned for their roles in coordinating funds transfers, including from the sale of Iranian oil, that benefit the IRGC-Qods Force (QF), and Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL).

Sep 23
Sep 23 Miran Sworns in as New Member of the Fed’s Board of Governors

Adam Witmer

Regulatory Update

On September 16, 2025, Dr. Stephen I. Miran took the oath of office as a member of the Board of Governors of the Federal Reserve System. The oath was administered by Judge Elizabeth L. Branch of the United States Court of Appeals for the Eleventh Circuit.

Sep 22
Sep 22 OFAC Published New Unblocking/Transfer Form

Adam Witmer

BSA, Regulatory Update

On September 19, 2025, the OFAC published a new Unblocking/Transfer Report Form to support compliance with reporting requirements under the Reporting, Procedures and Penalties Regulations. According to the OFAC, the new form offers a simplified way to report property that has been unblocked or transferred, which eases the burden on filers and improves OFAC's processing efficiency.

Oct 8
Oct 8 OCC and FDIC Issue Proposals Aimed at Refocusing Bank Supervision

Oct 7
Oct 7 OCC Eases Regulatory Burden for Community Banks

Oct 6
Oct 6 FinCEN Requests Comments on the Renewal of Information Sharing Requirements

Oct 2
Oct 2 Agencies Issue Reminder to Institutions on Lending When the NFIP Is Unavailable

Oct 2
Oct 2 CFPB Finalizes 1071 Final Rule Compliance Extension

Oct 1
Oct 1 FinCEN Postpones Residential Real Estate Reporting Rule

Sep 29
Sep 29 NCUA Removes Reputational Risk from Supervisory Processes

Sep 24
Sep 24 Treasury Targets Financial Network Supporting Iran’s Military

Sep 23
Sep 23 Miran Sworns in as New Member of the Fed’s Board of Governors

Sep 22
Sep 22 OFAC Published New Unblocking/Transfer Form

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