In 2025, debanking initiatives continued to intensify, with new guidance, legislation, and other actions at both the federal and state levels aimed at so-called “discriminatory debanking.”
Federal and State Efforts Intensify Focus on ‘Debanking’
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CTA UPDATE: Eleventh Circuit Declares CTA Constitutional; Beneficial Ownership Reporting Requirements Remain Unchanged
The U.S. Court of Appeals for the Eleventh Circuit in National Small Business United vs. U.S. Department of the Treasury reversed the decision of the U.S. District Court for the Northern District of Alabama decision, which found that the Corporate
Congress Abolishes Certain Exemptions for Foreign Private Issuers; Will Now Require Compliance with Section 16(a) Beneficial Ownership Reporting For Directors and Officers
On Dec. 18, 2025, President Donald Trump signed the National Defense Authorization Act for Fiscal Year 2026 (NDAA) into law. The NDAA includes Section 8103, the Holding Foreign Insiders Accountable Act (HFIAA), which abolishes certain of the current exemptions for
Providing Useful Tools: FINRA Releases its 2026 Annual Regulatory Oversight Report, Together with a FINRA Unscripted Podcast Filled with Senior Leadership Insights
On December 9, 2025, the Financial Industry Regulatory Authority (FINRA) released both its 2026 FINRA Annual Regulatory Oversight Report (the “Report”), and a companion FINRA Unscripted podcast (the “Podcast”), featuring senior FINRA leaders providing insights about the Report.
Do Non-Bank Financial Institutions Pose a Systemic Risk?
This is the fourth in our series of GT Alerts reporting on the House of Lords Financial Services Regulatory Committee (the Committee) inquiry into the non-bank financial institutions (NBFI) sector.
SEC Division of Examinations 2026 Priorities
The Securities and Exchange Commission (SEC)’s Division of Examinations (Division) announced its 2026 examination priorities (Exam Priorities) on Nov. 17, 2025.
Non-Bank Lending in the Spotlight – Does the System of Calculating Regulatory Capital Require Revisiting?
In October’s GT Alert on non-bank lending, we focussed on whether there was a justification in banks being subject to regulatory capital requirements when non-bank financial institutions (NBFIs) were not. Professor Simon Gleeson’s evidence – that banks are permitted to
Path Cleared for Registered Representative-Owned PSEs To Receive Transaction-Based Compensation
On Nov. 17, 2025, the U.S. Securities and Exchange Commission (SEC) issued a No-Action Letter confirming that it will not recommend enforcement action if a registered representative-owned personal services entity (PSE) receives transaction-based compensation (TBC) without first registering as a
NYDFS Final Cybersecurity Rules – MFA, Asset Inventory, and Third-Party Risk
The last remaining provisions of the amendments to the New York Department of Financial Services’ (DFS) cybersecurity regulation called Part 500 came into effect Nov. 1, 2025.
CFPB Withdraws ‘Fine Print’ Rule
On Oct. 29, 2025, the Consumer Financial Protection Bureau (CFPB) withdrew its proposed rule that would have required certain nonbank financial companies subject to its supervisory jurisdiction to submit annual reports about their use of terms and conditions that attempt