Revised Policy Would Enable Greater Scope for Digital Asset-Related Activities by Uninsured State Member Banks ...

President Trump signed an Executive Order titled “Guaranteeing Fair Banking for All Americans.” The Order states that “[i]t is the policy of the United States that no American should be denied access ...

Summary The federal government shutdown commenced at midnight on October 1, 2025, and proposals to reopen the government failed on October 3, extending the shutdown further into the fourth quarter. On ...

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 ...

Sullivan & Cromwell LLP announced today that Adrienne A. Harris, Superintendent of the New York State Department of Financial Services (“DFS”) from August 2021 through October 2025, has re-joined the ...

On July 31, 2025, the CFTC’s Division of Market Oversight issued a letter in response to a request from industry associations regarding the CFTC’s regulations requiring swap reporting counterparties ...

n a speech delivered at the 25th anniversary gala for the University of Delaware’s Weinberg Center for Corporate Governance on October 9, the Chair of the SEC, Paul Atkins, stated that “[t]he view ...

The Sixth Circuit overturned a discovery order against FirstEnergy, reaffirming that internal investigations led by outside counsel are protected by attorney-client privilege. Sullivan & Cromwell ...

The SEC Division of Corporation Finance announced that it will not respond to no-action requests for the exclusion of Rule 14a-8 shareholder proposals, other than no-action requests to exclude a ...

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Acting FDIC Chairman Hill Offers Lessons Learned from 2023 Bank Failures and Discusses Potential Streamlining of Resolution Plan Requirements and Improvements to ...

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, ...