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Recent guidance, rulemakings, and enforcement actions from CFPB, OCC, FinCEN, FDIC, and SEC — filtered for financial institutions.

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Mar 11, 2026
CFPB Final Rule
Small Business Lending Data Collection Rule — Phase 2 Implementation Deadline
Lenders with 2,500+ covered originations in each of 2024 and 2025 must begin collecting Section 1071 small-business lending data by July 18, 2026. CFPB issued a supplemental compliance guide clarifying reportable application fields and data integrity requirements.
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Mar 7, 2026
OCC Interpretive Letter
Updated Guidance on Bank-Fintech Arrangements and Third-Party Risk
OCC Interpretive Letter 1179 clarifies that national banks partnering with fintech firms for deposit products remain fully responsible for BSA/AML compliance regardless of delegation agreements. Enhanced due diligence requirements apply to all fintech partners exceeding $100M in deposit facilitation.
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Mar 4, 2026
FinCEN FAQ Update
Beneficial Ownership Information — Reporting FAQ Revision (Set 4)
FinCEN published 23 new FAQs addressing edge cases in BOI reporting under the Corporate Transparency Act, including clarifications on reporting for dissolved entities, pooled investment vehicles, and foreign-owned U.S. subsidiaries. Reporting companies should review updates to Question C.9 regarding ownership thresholds.
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Feb 28, 2026
FDIC Supervisory Guidance
Revised Third-Party Risk Management Examination Procedures
FDIC examiners will now evaluate third-party risk management programs using updated procedures that place greater emphasis on concentration risk and exit strategy viability. Banks with more than 40% of critical operations outsourced to a single vendor face enhanced scrutiny beginning Q2 2026.
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Feb 24, 2026
SEC Enforcement Action
SEC Charges Three Investment Advisers for Cybersecurity Incident Disclosure Failures
The SEC imposed $18.5M in combined penalties on three registered investment advisers for failing to timely disclose material cybersecurity incidents under Regulation S-P. The enforcement actions signal active examination of Form ADV cybersecurity disclosures and 30-day incident notification requirements effective since 2024.
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Feb 19, 2026
CFPB Supervisory Highlight
CFPB Supervisory Highlights: BNPL and Earned Wage Access Products (Issue 35)
CFPB's latest Supervisory Highlights identifies UDAAP violations in Buy Now Pay Later and earned wage access programs, focusing on undisclosed fee structures and misleading autopay marketing. Institutions offering these products should audit disclosures against the examples cited before the next examination cycle.
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Feb 13, 2026
OCC Bulletin
OCC Bulletin 2026-5: Digital Asset Custody Activities — Updated Permissibility Framework
National banks and federal savings associations may now custody digital assets (including tokenized securities and stablecoins) under existing authority, provided they maintain written policies addressing private key management, client segregation, and insurance coverage. Banks must notify their OCC supervisory office at least 30 days before commencing digital asset custody.
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Feb 6, 2026
FinCEN Notice of Proposed Rulemaking
NPRM: Anti-Money Laundering Program Effectiveness Standards
FinCEN proposes requiring financial institutions to establish risk-based AML program "effectiveness" metrics, including SAR filing accuracy rates and transaction monitoring model validation documentation. The comment period closes April 7, 2026; final rule expected Q4 2026 with an 18-month implementation window.
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Jan 30, 2026
FDIC Final Rule
FDIC Finalizes Brokered Deposit Rule Amendments — Sweep Accounts Reclassified
The FDIC finalized amendments to its brokered deposit rule that reclassify certain bank-managed sweep account arrangements as brokered deposits, effective July 1, 2026. Affected institutions with less-than-well-capitalized status will need to obtain FDIC approval or unwind these programs within 90 days of rating change.
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Jan 22, 2026
SEC Staff Bulletin
SEC Staff Bulletin: AI Use in Investment Advice — Suitability and Disclosure Obligations
The SEC Division of Investment Management released a bulletin clarifying that broker-dealers and investment advisers using AI recommendation engines must ensure the systems meet existing suitability and best-interest standards. Firms must disclose AI involvement in personalized recommendations and document how the technology aligns with fiduciary obligations.
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Jan 15, 2026
CFPB Final Rule
Medical Debt Credit Reporting Restrictions Take Effect
CFPB's final rule prohibiting consumer reporting agencies from including most medical debt on credit reports became effective January 15, 2026. Creditors and debt collectors must update furnishing policies to exclude medical debt tradelines; ongoing reporting of pre-rule medical debt remains permissible through a 12-month safe harbor period.
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Jan 9, 2026
FinCEN Geographic Targeting Order
FinCEN Expands Real Estate GTOs to 30 Metropolitan Areas
FinCEN renewed and expanded Geographic Targeting Orders requiring title insurance companies to identify beneficial owners behind all-cash residential purchases exceeding $300K in 30 U.S. metro areas, down from the previous $500K threshold in 15 metros. Orders are effective January 9–July 8, 2026.
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Dec 18, 2025
OCC Examination Procedures
OCC Releases Updated Fair Lending Examination Procedures — AI Scoring Focus
The OCC updated its Fair Lending Examination Procedures to address algorithmic and AI-driven underwriting models, requiring examiners to test for disparate impact in model outputs and evaluate institutions' explainability frameworks. Banks using vendor-supplied credit models should obtain bias-testing documentation before Q1 2026 examinations.
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Dec 10, 2025
FDIC Financial Institution Letter
FIL-72-2025: Community Bank Leverage Ratio Adjusted to 9.5% for 2026
The FDIC, OCC, and Federal Reserve jointly announced that the Community Bank Leverage Ratio (CBLR) will remain at 9% through June 30, 2026 before stepping up to 9.5% in the second half of 2026. Qualifying community banks should model capital projections against the updated threshold for year-end 2025 planning.
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Dec 3, 2025
SEC Final Rule
Private Fund Adviser Compliance Rules — Quarterly Statement and Audit Requirements
SEC's final rules under the Investment Advisers Act require private fund advisers to deliver quarterly statements disclosing fees, expenses, and performance metrics to fund investors, and obtain annual audits by PCAOB-registered auditors. Advisers with $1.5B+ in private fund AUM must comply by March 14, 2026; smaller advisers have until September 14, 2026.
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