Each quarter, our financial institutions experts bring you the top headlines to keep you updated on regulatory compliance matters impacting banks and credit unions. Here’s the latest roundup of information you need to know. The topics covered in this update include:
- Lending compliance
- Other compliance
- Financial crimes, including anti-money laundering/countering the financing of terrorism
Lending compliance
Agencies issue guidance on lending to non-work authorized borrowers
On July 13, 2026, the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the National Credit Union Administration (NCUA) issued interagency guidance reminding financial institutions of their existing credit risk management obligations when lending to individuals not legally authorized to work in the United States. The guidance states that such borrowers may present elevated credit risk due to uncertainty regarding income stability, employment continuity, and repayment capacity. Financial institutions are encouraged to incorporate these risks into underwriting, documentation, portfolio management, and compliance processes while remaining consistent with applicable consumer protection laws.
FDIC board approves proposal to amend regulations regarding lending limits for bank insiders
The FDIC issued a Notice of Proposed Rulemaking on July 31, 2026, to amend regulations governing loans to bank insiders, including executive officers, directors, principal shareholders, and their related interests. The proposal would increase certain lending thresholds and establish an indexing mechanism to adjust those thresholds over time, reducing the need for future regulatory updates. The FDIC stated that the changes are intended to better reflect current economic conditions, reduce regulatory burden, and maintain appropriate safeguards applicable to insider lending. Public comments will be accepted for 60 days following its publication in the Federal Register.
Agencies rescind special purpose credit program guidance
On Aug. 25, 2026, the Consumer Financial Protection Bureau (CFPB), FDIC, Federal Reserve, NCUA, OCC, the Federal Housing Finance Agency (FHFA), the Department of Housing and Urban Development (HUD), and the Department of Justice (DOJ) rescinded the 2022 interagency statement on Special Purpose Credit Programs (SPCPs), intended to encourage responsible use of SPCPs. The agencies stated that rescission was necessary to prevent reliance on guidance that may be inconsistent with the CFPB’s revised Regulation B requirements and to reinforce that all SPCPs must comply with ECOA, Regulation B, and applicable Fair Housing Act requirements.
Other compliance
Agencies propose targeted changes to CRA regulations
The FDIC, Federal Reserve, and OCC issued a joint Notice of Proposed Rulemaking to amend the Community Reinvestment Act (CRA) regulations on July 31, 2026. The proposal would retain much of the CRA framework used prior to the 2023 CRA final rule, increase the focus on lending activities, and provide regulatory relief for banks with $10 billion or less in assets by exempting them from certain data collection, reporting, and evaluation requirements. The agencies stated the proposal is intended to reduce regulatory burden, provide greater clarity regarding CRA evaluations, and allow additional time to consider future changes to the CRA framework. Public comments will be accepted for 60 days following publication in the Federal Register.
Agencies propose third-party risk management guidance
On Sept. 11, 2026, the FDIC, Federal Reserve, OCC, and NCUA requested public comment on a proposed third-party risk management guidance that would replace existing agency guidance with a unified, principles-based framework. The proposal emphasizes tailoring oversight, due diligence, contract management, ongoing monitoring, and contingency planning to the specific risks posed by each third-party relationship, rather than applying a one-size-fits-all approach. Comments on the proposed guidance are due 60 days after publication in the Federal Register. In a related statement, the agencies acknowledged the reliance of community banks on core service providers and indicated that such reliance will be considered when making supervisory and enforcement decisions.
Financial crimes, including anti-money laundering/countering the financing of terrorism
Agencies clarify SAR confidentiality requirements
On Sept. 3, 2026, the FDIC, Federal Reserve, OCC, NCUA, and FinCEN issued a joint statement clarifying that while the Bank Secrecy Act prohibits disclosure of a Suspicious Activity Report (SAR), or information that would reveal its existence, financial institutions may generally discuss suspicious or potentially fraudulent activity with customers and notify customers of account closures related to such activity. Institutions should ensure that communications don’t reveal the existence of a SAR and should evaluate customer communications on a case-by-case basis.
FinCEN ends beneficial ownership reporting requirements
On Aug. 11, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule adopting the exemptions established under its March 2025 interim final rule, permanently exempting U.S. companies and U.S. persons from beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act. The rule also exempts foreign reporting companies from reporting BOI relating to U.S. beneficial owners and applicants, revises reporting requirements for certain foreign pooled investment vehicles, and eliminates requirements for U.S. persons to update or correct FinCEN identifier information. FinCEN also stated that it’ll remove previously reported information relating to U.S. persons from the BOI database.
