Overview (Program Summary)
One year into the second Trump Administration, banks and other financial intermediaries continue to grapple with a bewildering series of Executive Orders, lawsuits, and withdrawn or cancelled regulations, RIFs and policy changes—with the scope of examination and supervision priorities continuing to evolve. After months of an aggressive shift toward deregulation, including the rollback of regulatory initiatives adopted by the Biden Administration on topics such as fair lending, in the second half of 2025, the Trump Administration’s new regulatory agenda began to take shape, including debanking prohibitions and new rulemaking under Section 1033, among others initiatives. These changes pose both opportunities and challenges for the financial services industry.
This Legal Update will address recent policy shifts in approach with a view toward enabling clients and friends to begin to identify: (a) regulatory policies that will apply going forward; (b) how the financial regulators may modify examination, supervision and enforcement; and (c) how court challenges may limit claimed Administration overreach.
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