Early 2026 developments from the Farm Credit Administration (FCA) show the regulator is identifying opportunities to reduce regulatory complexity while reinforcing risk management expectations across Farm Credit System (FCS or System) institutions.
On April 24, 2026, the Office of the Comptroller of the Currency (OCC) issued two coordinated interim final actions:
- an Interim Final Rule amending 12 CFR § 7.4002 governing national bank non‑interest charges and fees (the “Interim Final Rule”)[1], and
- an Interim Final Order preempting Illinois’s Interchange Fee Prohibition Act (IFPA) under the National Bank Act (NBA) and Home Owners’ Loan Act (HOLA) (the “Interim Final Order”).
Together, these actions are intended to reaffirm the authority of national banks under federal law to earn and receive interchange fees and to prevent the imminent application of Illinois’s first‑of‑its‑kind state interchange fee restrictions to OCC‑regulated institutions. Both actions are effective June 30, 2026, and both are subject to a post‑issuance comment period.
In March 2026, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (the “Federal Reserve”), and the Federal Deposit Insurance Corporation (FDIC, and together with the OCC and Federal Reserve, the “Agencies”) released a set of proposals that would significantly recalibrate U.S. bank capital requirements across banking organizations of all sizes, including:
Moore & Van Allen attorneys Kate Wellman, John Stoker, and Neil Bloomfield have published a new Law360 Expert Analysis, “Recent Bank Resolution Filings Stress Readiness Over Docs,” examining what recent bank resolution plan filings reveal about how institutions and regulators are approaching preparedness.
Tanisha Palvia and Tiffany Payne explore this topic in a recently published article in Dow Jones Risk Journal: “State False Claims Laws: An Overview of the Evolving Landscape and Recent Enforcement Trends.”
Moore & Van Allen Members Valecia McDowell and Tanisha Palvia have published expert analysis in Law360 examining recent federal court rulings that cast doubt on the enforceability of anti‑DEI grant conditions tied to federal public safety funding.
The 2026 ABA Banking Law Committee Meeting held in Washington, DC from January 15-17 delivered significant content in just over two full days of sessions. Conversations with state and federal regulators, agency general counsels, and practitioners reveal a regulatory landscape in transition. Below we summarize the following four themes from the meeting shaping the future of bank supervision, enforcement, and policy:
- The federal banking agencies are entering 2026 with a broad and active regulatory agenda, including continued focus on tailoring and capital and additional focus ...
Key Financial Regulatory Developments
2025 brought one of the most dynamic financial regulatory environments since the immediate aftermath of Dodd‑Frank, marked by shifting agency priorities, rapid litigation developments, and evolving supervisory philosophies.
The Department of Justice recently announced, “[i]n the first [criminal] prosecution of its kind,” that husband and wife owners of wound graft companies were sentenced to 14.5 and 15 years imprisonment respectively for causing over $1.2 billion in false claims to be submitted to Medicare Part B and other federal health care programs for medically unnecessary wound grafts. The defendants pled guilty to conspiracy to commit health care and wire fraud and were ordered to pay more than $1.2 billion in restitution and forfeit approximately $410 million in fraudulent proceeds ...
UPDATE:
On April 23, 2026, the Federal banking agencies finalized a rule modifying the community bank leverage ratio (CBLR). The final rule adopted the November 2025 proposed CBLR modifications without change and will take effect July 1, 2026.
The Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation, and the Federal Reserve Board (collectively, the “Agencies”) have jointly issued a Notice of Proposed Rulemaking (NPR) that, if finalized as proposed, could provide significant regulatory relief for community banks. The proposal seeks to ...
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The latest from MVA White Collar Defense, Investigations, and Regulatory Advice Blog
- Farm Credit Administration’s 2026 Priorities Reflect Some Alignment with Federal Banking Regulators, With Continued Focus on Risk Management and System‑Specific Nuances
- OCC Responds to the District Court’s Decision in Illinois Bankers Association v. Raoul by Issuing Interim Final Actions Addressing State Interchange Fee Laws and Federal Preemption
- Capital Recalibration: Overview of the 2026 Basel III, Revised Standardized Approach, and GSIB Surcharge Proposals
- Law360 Expert Analysis: Recent Bank Resolution Filings Stress Readiness Over Docs