All in Regulatory Update

FinCEN Proposes Rule to Sever Swiss Bank MBaer’s Access to U.S. Financial System

Adam Witmer
BSA, Regulatory Update

On February 26, 2026, FinCEN issued a proposed rule that, if finalized, would sever MBaer Merchant Bank AG (MBaer’s) access to the U.S. financial system as a result of its financial support to illicit actors linked to Russia and Iran.  If finalized, the proposed rule would prohibit covered U.S. financial institutions from opening or maintaining a correspondent account for, or on behalf of, MBaer.

Federal Reserve to Hold Hybrid Meeting on EGRPRA Review

Adam Witmer
Regulatory Update

On February 19, 2026, the Federal Reserve Board announced that it will hold a hybrid public outreach meeting on March 26, 2026, as part of its review of regulations under the Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA). EGRPRA mandates that the Board, with public input, review its regulations every 10 years to identify outdated or unnecessarily burdensome requirements for certain supervised institutions.

Bowman on Revitalizing Bank Mortgage Lending

Adam Witmer
Regulatory Update

On February 16, 2026, Vice Chair for Supervision Michelle Bowman spoke at the American Bankers Association 2026 Conference for Community Bankers, where she talked about the significant migration of mortgage origination and servicing from banks to nonbanks and the regulatory factors that may be driving this shift. In her speech, Bowman highlighted a long-term contraction in bank participation in the mortgage market. 

FinCEN Issues Exceptive Relief to Streamline CDD Requirements

Adam Witmer
BSA, Regulatory Update

On February 13, 2026, FinCEN issued an order granting exceptive relief to covered financial institutions from certain requirements under FinCEN’s Customer Due Diligence Requirements for Financial Institutions rule. The order exempts covered financial institutions from the requirement to identify and verify the beneficial owners of a legal entity customer each time the customer opens a new account.

FHFA Repeals Fair Lending, Fair Housing, and Equitable Housing Finance Plans Regulations

Adam Witmer
Regulatory Update

On February 6, 2026, the Federal Housing Finance Agency (FHFA) issued a final rule to repeal the Fair Lending, Fair Housing, and Equitable Housing Finance Plans regulation (Part 1293). Part 1293 codified the FHFA’s fair housing and fair lending oversight of the regulated entities, the Enterprise Equitable Housing Finance Plan (EHFP) program, and requirements for the Enterprise to collect a borrower's language preference and housing counseling and homeownership education information.

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