To our clients and friends:
We have updated our monthly Bankers’ Bulletin publication with a revised presentation format, featuring new content and additional practical tips to help banks implement the regulatory developments we cover. Today we published Volume 22, which provides our insights into key banking industry developments from September 2025, including:
- The FDIC’s removal of references to disparate impact;
- The OCC’s guidance on considering debanking in licensing and CRA reviews;
- A federal circuit court’s rejection of Jarkesy as applied to bank enforcement;
- The FDIC’s loosened standards for removing cease-and-desist orders;
- FinCEN guidance on cross-border information sharing;
and more.
A link to the latest edition of the Bulletin is available here. If you have any questions related to any of the items covered in this edition of the Bulletin, please reach out to Brendan Clegg (bclegg@luselaw.com), Marc Levy (mlevy@luselaw.com), Scott Brown (sbrown@luselaw.com), Keeler Fina (kfina@luselaw.com), or your regular Firm contact. To learn more about Luse Gorman, please visit our website.