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Q1 2026 compliance updates for financial institutions

March 26, 2026 / 6 min read

Our experts cover the top headlines each quarter to keep you apprised of regulatory compliance matters impacting banks and credit unions. This quarter, we highlight several proposed rulemakings and other supervisory guidance to help navigate the current regulatory environment.

Lending compliance

CFPB and DOJ withdraw noncitizen fair lending guidance

On Jan. 12, 2026, the Consumer Financial Protection Bureau (CFPB) and the Department of Justice (DOJ) withdrew their October 2023 joint statement addressing how lenders consider immigration or citizenship status under the Equal Credit Opportunity Act (ECOA). The agencies stated the withdrawal was intended to avoid confusion and ensure alignment with ECOA and Regulation B, which permit creditors to consider lawful residence or immigration status when necessary for creditworthiness and protection of repayment rights while maintaining prohibitions on discrimination based on protected characteristics.

OCC eliminates Fair Housing Home Loan Data System to reduce regulatory burden

In OCC Bulletin 2026-5, issued on March 3, 2026, the Office of the Comptroller of the Currency (OCC) finalized a rule rescinding 12 CFR Part 27, the Fair Housing Home Loan Data System. The OCC determined that Part 27 was obsolete, duplicative, and inconsistent with other federal laws requiring home loan data collection, and that the data had limited supervisory value. Rescinding the rule eliminates unnecessary regulatory burden for national banks and their subsidiaries without materially affecting the OCC’s ability to conduct fair-housing-related supervision. The final rule becomes effective 30 days after publication in the Federal Register.

Executive order on promoting access to mortgage credit

On March 13, 2026, the president issued an executive order titled, “Promoting Access to Mortgage Credit,” directing federal financial regulators to review and consider changes intended to reduce regulatory burden and expand access to mortgage lending, particularly for community banks and smaller institutions. The order asserts that postDoddFrank regulatory requirements have increased compliance costs and discouraged bank participation in mortgage origination and servicing. It instructs agencies such as the CFPB, Federal Deposit Insurance Corporation (FDIC), OCC, Federal Reserve, National Credit Union Administration (NCUA), and Federal Housing Finance Agency (FHFA) to explore potential reforms through future rulemaking or guidance, including tailoring ability to repay and qualified mortgage requirements, revisiting TRID disclosure timing, and adjusting points-and-fees thresholds for small balance loans. The order emphasizes a shift toward supervisory approaches that focus on prudent underwriting and borrower ability to repay, rather than technical compliance errors. The executive order doesn’t amend existing laws or regulations and doesn’t create immediate compliance obligations. Instead, it signals a change in regulatory direction that may influence future mortgage-related compliance requirements and examiner focus.

Other compliance

Risk-focused oversight continues: NCUA sets 2026 supervisory priorities

On Jan. 14, 2026, the NCUA issued its 2026 Supervisory Priorities Letter to credit unions, reaffirming its commitment of “no regulation by enforcement” while emphasizing safety and soundness through risk-based supervision. The letter outlines examination priorities for the year, including risk-focused exams tailored to each credit union’s risk profile, heightened attention to balance sheet management and lending practices amid weakened loan performance, continued focus on operational and compliance risks such as fraud prevention and consumer protection, and efforts to improve exam efficiency and innovation, including alignment with recent legislative directives like the GENIUS Act.

FDIC extends comment period for GENIUS Act stablecoin rules

The FDIC announced a 90-day extension to the public comment period for its proposed rule establishing application procedures under the GENIUS Act for FDIC-supervised state nonmember banks and state savings associations seeking to issue payment stablecoins through subsidiaries. The extension is intended to give stakeholders additional time to review and respond to the proposal. As a result, the comment deadline has been moved from Feb. 17, 2026, to May 18, 2026.

Fed moves to end ‘reputation risk’ in supervision, seeks public comment

On Feb. 23, 2026, the Federal Reserve Board (FRB) requested public comment on a proposal to formally codify the removal of “reputation risk” from its bank supervision framework. Building on earlier actions announced in June, the proposal reinforces the Fed’s policy that banks should not be penalized for serving customers engaged in lawful activities, including those with particular political views, religious beliefs, or involvement in legally permissible, but controversial, industries. The board emphasized that supervisory decisions should be grounded in material financial risks while maintaining expectations for strong risk management, safety and soundness, and compliance with applicable laws. Comments are due within 60 days after publication in the Federal Register.

OCC proposes comprehensive rules to implement the GENIUS Act

On Feb. 25, 2026, the OCC issued a notice of proposed rulemaking to implement the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act. The proposal seeks public comment on regulations that would apply to permitted payment stablecoin issuers and foreign payment stablecoin issuers under OCC jurisdiction, as well as certain stablecoin-related custody activities conducted by OCC-supervised entities. The proposed rule addresses all GENIUS Act requirements assigned to the OCC except those related to BSA (Bank Secrecy Act), AML (anti-money laundering), and OFAC (Office of Foreign Assets Control) sanctions, which will be covered in a separate Treasury-coordinated rulemaking. Public comments are due 60 days after publication in the Federal Register. The proposal would implement most GENIUS Act requirements through a new 12 CFR Part 15, and would apply to a broad range of OCC-supervised banks, nonbank payment stablecoin issuers, and certain foreign and state-qualified issuers with conforming amendments to existing capital and supervisory regulations.

FDIC approves final rule to amend official signs and advertising requirements

The FDIC board approved a final rule amending official signs and advertising requirements to simplify and clarify how banks display the FDIC digital sign and nondeposit disclosures across websites, mobile apps, and ATMs. The rule narrows where signage is required to screen most relevant to consumers, provides greater design flexibility for the FDIC digital sign, and reduces unnecessary or repetitive disclosures, addressing implementation issues from the 2023 rule. The amendments are effective March 2, 2026, with a compliance date of April 1, 2027.

NCUA deregulation proposals

The National Credit Union Administration (NCUA) continued its Deregulation Project through several rounds of proposals aimed at reducing compliance burden by eliminating outdated, duplicative, or overly prescriptive requirements while maintaining safety and soundness. On Jan. 13, 2026, the NCUA’s third round proposed, among other items, removing 12 CFR Section 701.31 (nondiscrimination requirements) and rescinding certain Interpretive Ruling and Policy Statements (IRPS) tied to topics like service to underserved areas and chartering guidance. On Jan. 27, 2026, the fourth round proposed targeted relief such as easing requirements related to public unit and nonmember shares, eliminating mandatory 30-day notice periods for terminating supplemental share insurance, removing maximum borrowing authority limits for certain state-chartered credit unions, and rescinding select share insurance disclosure requirements. On Feb. 10, 2026, the fifth round focused on streamlining structural transitions by proposing changes to simplify credit union conversions to mutual savings banks, easing certain merger and insurance conversion disclosure requirements, and rescinding IRPS 061 where the topic is now addressed in the Chartering Manual. On Feb. 24, 2026, the sixth round advanced six additional deregulatory proposals spanning items such as board training, loan compensation incentives, eligible obligations, interest refunds, service contracts, and statutory lien definitions, generally intended to reduce prescriptive compliance burdens and add operational flexibility. On March 10, 2026, the seventh round proposed modernizing records preservation and catastrophic act preparedness (12 CFR Part 749) by narrowing and clarifying the focus to “vital records,” removing guidance-only appendices, permitting electronic record logs, allowing disposal of outdated records where permitted, and reinforcing oversight expectations for third-party recordkeeping providers.

Financial crimes, including anti-money laundering/countering the financing of terrorism

FinCEN streamlines beneficial ownership checks with targeted CDD relief

On Feb. 13, 2026, the Financial Crimes Enforcement Network (FinCEN) issued an order granting relief from certain requirements of its 2016 Customer Due Diligence (CDD) Rule. The order eliminates the requirement for covered financial institutions to identify and verify beneficial owners of a legal entity customer at each new account opening. Instead, institutions must perform beneficial ownership identification and verification only when the customer first opens an account, when the institution becomes aware of information that calls into question the reliability of previously obtained information, or as otherwise required under the institution’s risk-based ongoing CDD procedures. FinCEN emphasized that all other Bank Secrecy Act and AML/CFT obligations remain fully in effect, and characterized the action as reducing duplicative burden while supporting a more efficient, risk-based approach to customer due diligence.

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