What's New? Managing Risk Associated with TPSPs

    The New York State Department of Financial Services issued a letter on October 21, 2025 to assist regulated entities in managing the evolving cybersecurity risks associated with Third-Party Service Providers (TPSPs) that have access to sensitive nonpublic information. The guidances emphasizes a proactive, risk-based approach that spans the entire relationship lifecycle, including initial due diligence, robust contracting, continuous monitoring, and secure termination. Senior Governing Bodies and Senior Officers must remain engaged in oversight, as they are ultimately responsible for compliance and cannot delegate regulatory obligations to outside vendors. To protect data integrity, NYDFS recommends specific contractual safeguards such as multi-factor authentication, data encryption, and mandatory notification of cybersecurity incidents.

See the letter here and our section in the Gold Book.

What's New? BNPL Loan Protections in NY

Governor Kathy Hochul announced, on February 23, 2026, proposed regulations to establish a comprehensive licensing and supervision framework for all Buy Now, Pay Later (BNPL) providers operating in New York. These rules are specifically designed to prevent consumer debt spirals by prohibiting excessive junk fees and placing strict limits on late payment penalties. The regulations also mandate transparent loan disclosures regarding credit reporting, establish standards for the timely resolution of disputes, and provide strong protections for consumer data. Following a public comment period, this new oversight framework is scheduled to take effect 180 days after its official adoption.

For more information on the proposed rule, see our section in the Gold Book.

What's New? SBA Revised Citizenship and Residency Loan Requirements

Effective March 1, 2026, the Small Business Administration (SBA) implemented significant updates to the citizenship and residency requirements for its 7(a) and 504 loan programs. Under this new policy, 100% of a small business applicant's direct and indirect owners must be U.S. Citizens or U.S. Nationals. Furthermore, all owners are now required to maintain their principal residence within the United States, its territories, or possessions. These changes officially rescind previous exceptions for minority foreign ownership and clarify that Legal Permanent Residents (LPRs) are no longer eligible to hold any ownership interest in a borrowing entity. Business owners and lenders with questions regarding these stricter eligibility standards should contact their local SBA Field Office for guidance.

For details see the policy notice and our section in the Gold Book.

What's New? Fee for Receiving Paper Statements is Constitutionally Protected

The United States District Court  for the Eastern District of New York has ruled that New York General Business Law Section 399-zzz is unconstitutional. This statute previously prohibited business entities from charging consumers an additional fee for receiving paper billing statements. Following this decision, banks have stronger legal grounds to defend the imposition of paper statement fees in New York, though operational caution is still advised due to the potential for appeals.

For more details, see our section in the Gold Book.

What's new? NYC Debt Collection Restrictions and Requirements

The New York City Department of Consumer and Worker Protection (DCWP) has adopted Amended Rules governing debt collection from NYC consumers, effective September 1, 2026. These rules introduce significant changes for financial institutions, as they expand the definition of "debt collector" to include original creditors and impose strict operational requirements.

For more details, see our section in the Gold Book.

What's New? FinCEN issues final rule reducing requirements for Beneficial Ownership reporting

On February 13, 2026, FinCEN issued a final rule that grants exceptive relief from the requirements in 31 C.F.R. § 1010.230(b), which previously required covered financial institutions to identify and verify the beneficial owners of legal entity customers at each new account opening. The ruling changes these requirements by allowing institutions to limit identification and verification to three broad scenarios instead of every time an account is opened.

For details see the final rule and our section in the Gold Book.

What's New? FDIC Final Rule Streamlines Branch Openings and Relocations

The Federal Deposit Insurance Corporation (FDIC) has adopted a Final Rule to modernize the process for insured State nonmember banks to establish branches or relocate offices. Effective February 27, 2026, these changes are designed to reduce regulatory burdens, improve speed, and provide greater certainty for banks.

See the full publication and our section in the Gold Book.

What's new? FDIC Signage Rules: Streamlining Digital and ATM Disclosures

The Federal Deposit Insurance Corporation (FDIC) has issued a final rule amending signage requirements for digital deposit-taking channels and automated teller machines (ATMs). This update is designed to offer greater flexibility to insured depository institutions (IDIs) while ensuring consumers clearly understand when their funds are protected by federal deposit insurance.

The changes aim to reduce the administrative burden on banks—estimated to save the industry over $10.2 million in implementation costs—while minimizing consumer confusion.

See the full rule here and our updated section in the Gold Book.

What's New? New York State requires lenders to honor payments according to their specific instructions

Recent legislative changes in New York State now mandate that mortgage lenders honor payments submitted according to their specific instructions. Under this updated law, financial institutions are strictly required to accept funds delivered to the designated location if the borrower followed the directions provided in a payoff statement. This measure ensures that homeowners can reliably settle their debt obligations without the risk of their payments being rejected unexpectedly. By enforcing compliance with these official documents, the state aims to provide greater legal protection and transparency for consumers during the loan satisfaction process. This development effectively prevents lenders from disregarding transactions that align with their own documented requirements.

For more details see the full amendment.

What's New? Updated thresholds for Regulations M, V, and Z

Effective January 1, 2026, five final rules issued by the CFPB will increase various regulatory dollar thresholds for Regulations M, V, and Z. These updates include higher loan amount triggers for high-cost mortgages and Qualified Mortgages, as well as an increases to exemption thresholds. For more information, see the corresponding releases:

Regulation Z (Annual Threshold Adjustments)

Higher-priced Mortgage Exemption

Regulation Z (TILA)

Regulation M

Regulation V

What's New? OCC proposes new strategic plan for community banks to meet CRA requirements

Last month, the Office of the Comptroller of the Currency (OCC) introduced a proposed simplified strategic plan to help community banks more efficiently meet Community Reinvestment Act (CRA) requirements while reducing their regulatory burden. The public is invited to provide comments on the proposal for a 60-day period, beginning December 17 2025. For more info, see the OCC News Release 2025-129.

What's New? IRS and OCC Recent Updates!

The IRS and Treasury Department have published guidance and announced plans to issue regulations for “Trump Accounts,” which are a new type of individual retirement account for children created by Congress earlier this year.

 

The OCC and the FDIC are rescinding the “Interagency Guidance on Leveraged Lending” dated March 21, 2013, and the “Frequently Asked Questions for Implementing March 2013 Interagency Guidance on Leveraged Lending” dated November 7, 2014. The agencies say they expect banks to manage leveraged lending exposures consistent with general principles for safe and sound lending.

 

The OCC is updating guidance that applies to commercial loans to companies in an early, expansion, or late stage of corporate development. The agency's new bulletin refers to these loans as “venture loans” and provides transparency into the OCC’s supervisory approach and application of existing laws, regulations, and guidance. Specifically, the updated guidance reflects the OCC’s policy of not discouraging banks from engaging in prudent venture lending activities.

 

Stay tuned to the Gold Book as we move closer to the New Year and all its new changes!

What's New? Minimum Wage Increase in New York State

We remind you that the the minimum wage in New York State will increase by an additional 0.50 cents per hour starting January 1, 2026. This adjustment sets the new minimum wage at $17.00 per hour for New York City, Westchester, and Long Island, and $16.00 per hour for the rest of the state. Governor Hochul notes that this increase is intended to help lighten the burdens of inflation and rising costs of living for the lowest earners across the state. This change is part of a multiyear agreement that schedules subsequent annual increases starting in 2027 which are indexed to regional inflation.

For more information visit the NY State website.Save & Close

What's New? OCC Proposes Lowering Capital Requirements for Community Banks: A CBLR Update

The Office of the Comptroller of the Currency (OCC), alongside the Federal Reserve and the Federal Deposit Insurance Corporation (collectively, the federal banking agencies), is requesting public comment on a proposed rule aimed at relieving regulatory burden on certain community banks. This proposal amends the existing Community Bank Leverage Ratio (CBLR) framework.

See more on the OCC's bulletin.

What's New? Cost-of-Living Adjusted Limitations for 2026

The IRS published Notice 2025-67 on November 13, 2025, adjusting annual limitations for contributions to retirement plans annd IRAs. Check out our update page in the Gold Book and the IRS news release!

What's New? CFPB proposed changes to Section 1071

The Consumer Financial Protection Bureau (CFPB) has issued a new proposed rule to substantially revise the 2023 small business lending data collection and reporting rule under Section 1071, aiming to reduce regulatory burden and ensure the long-term success of the data collection regime by initially commencing with a narrower scope. To focus on core lenders and businesses, the proposal raises the covered financial institution origination threshold from 100 to 1,000 transactions, excludes products like merchant cash advances and agricultural lending, and changes the small business gross annual revenue definition from 5 million or less to 1 million or less. Additionally, the CFPB proposes removing discretionary data points, such as pricing information and denial reasons, to focus on statutory requirements, and setting a single compliance date of January 1, 2028, for all institutions above the new threshold.

Stay tuned as the proposed rule progresses through regulatory bodies.

What's New? Two joint notices of rulemaking from the OCC and FDIC

The OCC and FDIC have proposed two joint notices of rulemaking intended to shift supervisory focus primarily onto material financial risks. One of these rules, released October 7, specifically addresses reputation risk by codifying its elimination from supervisory programs. Under this proposed reputation risk rule, examiners would be prohibited from criticizing or taking adverse action against a bank, or encouraging account closures, based solely on a person or entity’s political, social, cultural, or religious views, constitutionally protected speech, or lawful but politically disfavored business activities perceived to present reputation risk. The second proposed rule, also released October 7, establishes a uniform definition for the term “unsafe or unsound practice”. This definition includes a practice that is "contrary to generally accepted standards of prudent operation". Additionally, the practice must be likely to materially harm the financial condition of the bank, present a material risk of loss to the Deposit Insurance Fund, or already have materially harmed the bank’s financial condition. This proposal also revises the issuance framework for Matters Requiring Attention (MRAs), allowing them only for defined unsafe or unsound practices or violations of banking or banking-related laws.

For more details, see OCC bulletins 2025-29 and 2025-30.

What's New? Federal Regulatory Changes Incoming

Federal regulators are driving significant shifts to tailor and modernize supervision, focusing on reducing regulatory burden for community banks by adjusting examination frequency and scope based on risk, and concentrating oversight specifically on material financial risks. In a major joint effort, the OCC and FDIC proposed rules to codify the elimination of reputation risk from their supervisory programs, prohibiting adverse actions against institutions solely based on customers' political, religious views, or lawful but politically disfavored business activities. To enhance regulatory clarity, five agencies—the OCC, FinCEN, Federal Reserve Board, FDIC, and NCUA—issued joint FAQs regarding Suspicious Activity Reports (SAR) and Bank Secrecy Act reporting; separately, the Federal Reserve released guidance and templates to clarify capital instruments for mutual banking organizations, building on a recent OCC authorization for an innovative mutual capital certificate. Finally, the Federal Reserve plans operational expansion for the Fedwire Funds Service and National Settlement Service to include Sundays and weekday holidays, though implementation is scheduled for 2028 or later.

Stay tuned as developments are finalized!

What's New? Supervision and Regulation Letter 25-4

Yesterday, October 10, 2025, the Board of Governors of the Federal Reserve System issued Supervision and Regulation (SR) Letter 25-4, with the aim to distribute and introduce Frequently Asked Questions (FAQs) regarding suspicious activity report (SAR) requirements. These FAQs serve to clarify existing regulatory obligations for financial institutions concerning SARs, which are deemed a critical tool for combating financial crime. The letter emphasizes that these answers do not alter current Bank Secrecy Act (BSA) legal requirements but aim to assist institutions in compliance and optimizing their reporting resources for law enforcement value.

For more details, see the FAQs here.

What's New? IRS Issues Final Roth Catch-Up Regulations

Starting in 2026, employees earning more than $145,000 in prior year FICA wages are required to make 401(k) and 403(b) catch-up contributions as Roth. This mandate requires extensive payroll coordination and planning in order to administer catch-up and Roth deferrals.

See our section in the Gold Book for more details!