Alert – Volume 23 of The Bankers’ Bulletin

November 10, 2025

To our clients and friends:
Today we published Volume 23 of The Bankers’ Bulletin, which provides our insights into key banking industry developments from October 2025, including:
• The OCC and FDIC’s proposal on MRAs and unsafe and unsound practices;
• FinCEN’s FAQs on SAR filing and documentation;
• FRB guidance on mutual bank organization capital instruments;
• NYDFS guidance on cybersecurity and enforcement actions;
• OCC actions to ease community bank burdens;
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.

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Alert – SEC Permits Use of Standing Proxies

September 29, 2025

To our clients and friends:

On September 15, 2025, the SEC issued a no-action letter in response to Exxon Mobil Corporation’s request to implement a "retail shareholder voting program" whereby its retail shareholders would authorize the perpetual voting of their shares in favor of management’s recommendations. Our Legal Update, available [here], describes the requirements for— and potential ramifications of— implementing a standing proxy program. Our Legal Update also offers tips for public holding companies interested in pursuing the use of standing proxies.

Luse Gorman, PC regularly advises companies regarding corporate governance, shareholder matters and SEC developments. If you have any questions related to this Legal Update, please contact the authors. To learn more about our firm and services, please visit our website.

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