On November 7, 2025, the FDIC revised its Consumer Compliance Examination Manual to reflect an updated examination frequency schedule whereby consumer compliance examinations and Community Reinvestment Act (CRA) evaluations will occur less frequently for most institutions. The update also establishes a new compliance mid-point risk analysis for certain institutions.

Nov 5
Nov 5 Treasury Sanctions DPRK Bankers for Cybercrime Funds Laundering

Adam Witmer

BSA, Regulatory Update

On November 4, 2025, the OFAC sanctioned eight individuals and two entities for their role in laundering funds derived from a variety of illicit Democratic People’s Republic of Korea (DPRK) schemes, including cybercrime and information technology (IT) worker fraud. According to the Multilateral Sanctions Monitoring Team’s report, these operations have been linked to the funding for the DPRK’s weapons of mass destruction (WMD) programs and destruction of physical computer equipment.

Nov 3
Nov 3 Fed to Reduce its Bank Supervision Staff by 30%

Adam Witmer

Regulatory Update

On October 30, 2025, the ABA Banking Journal cited a report by the Wall Street Journal that the Federal Reserve will reduce its bank supervision staff by 30% by the end of 2026.

Nov 3
Nov 3 Court Issues Temporary Pause on Enforcement of Section 1033 Rule

Adam Witmer

Regulatory Update

On October 29, 2025, the ABA Banking Journal reported that a federal court issued an order preventing the CFPB from enforcing its rule on financial data sharing while the bureau reassesses the regulation. The CFPB finalized the rule in October 2025 that requires financial institutions, credit card issuers, and other financial providers to unlock an individual’s personal financial data and transfer it to another provider at the consumer’s request for free.

Oct 30
Oct 30 CFPB Rescinds Registry of Nonbank Covered Persons Final Rule

Adam Witmer

Regulatory Update

On October 29, 2025, the CFPB issued a final rule rescinding its rule requiring certain types of nonbank covered persons subject to certain final public orders obtained or issued by a government agency in connection with the offering or provision of a consumer financial product or service to report the existence of the orders and related information to a Bureau registry.

Oct 28
Oct 28 CFPB Says FCRA Preempts State Laws

Adam Witmer

FCRA, Regulatory Update

On October 28, 2025, the CFPB published an interpretive rule to clarify that the Fair Credit Reporting Act (FCRA) generally preempts State laws that touch on broad areas of credit reporting, consistent with Congress's intent to create national standards for the credit reporting system. The interpretive rule replaces a July 2022 interpretive rule that the Bureau withdrew in May 2025.

Oct 23
Oct 23 FinCEN Report Reveals $9 Billion in Iranian Shadow Banking Activity in 2024

Adam Witmer

Regulatory Update, BSA

On October 23, 2025, FinCEN published a Financial Trend Analysis (FTA) identifying approximately $9 billion of potential Iranian shadow banking activity that occurred through U.S. correspondent accounts in 2024. The analysis draws on reports from U.S. financial institutions about transactions before the maximum pressure campaign and supplements FinCEN’s June advisory on Iran’s illicit oil smuggling, shadow banking, and weapons procurement activities.

Oct 22
Oct 22 Senators Introduce Bill to Increase BSA Reporting Limits

Adam Witmer

BSA, Regulatory Update

On October 21, 2025, the Senate proposed a bill that would raise the reporting thresholds for currency transaction reports and suspicious activity reports. If enacted, the bill would require the Treasury Department to adjust the thresholds for inflation every five years.

Oct 22
Oct 22 NCUA Proposes to Prohibit the Use of Reputation Risk

Adam Witmer

Regulatory Update

On October 21, 2025, the NCUA issued a a notice of proposed rulemaking to codify the elimination of reputation risk from its supervisory program. The FDIC and the OCC previously issued a joint proposal to formalize the elimination of reputation risk from their supervisory programs.

Oct 21
Oct 21 OCC Comptroller Gould Details Steps to Support Community Banks

Adam Witmer

Regulatory Update

On October 20, 2025, Comptroller of the Currency Jonathan Gould spoke at the American Bankers Association Annual Convention in Charlotte, North Carolina. Gould stated that his focus as a banking regulator is to rectify the regulatory overreach that has occurred since the 2008 financial crisis, especially regarding the community bank sector.

Nov 10
Nov 10 FDIC Revises its Consumer Compliance Exam Schedule

Nov 5
Nov 5 Treasury Sanctions DPRK Bankers for Cybercrime Funds Laundering

Nov 3
Nov 3 Fed to Reduce its Bank Supervision Staff by 30%

Nov 3
Nov 3 Court Issues Temporary Pause on Enforcement of Section 1033 Rule

Oct 30
Oct 30 CFPB Rescinds Registry of Nonbank Covered Persons Final Rule

Oct 28
Oct 28 CFPB Says FCRA Preempts State Laws

Oct 23
Oct 23 FinCEN Report Reveals $9 Billion in Iranian Shadow Banking Activity in 2024

Oct 22
Oct 22 Senators Introduce Bill to Increase BSA Reporting Limits

Oct 22
Oct 22 NCUA Proposes to Prohibit the Use of Reputation Risk

Oct 21
Oct 21 OCC Comptroller Gould Details Steps to Support Community Banks

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