A bank regulatory wire service On the wire

BankRegWire.

A working catalogue of U.S. financial services regulation, filed from the primary source, with conclusions front-loaded and rule text read closely.

Edition VI · MMXXVI
Desks five
Filed from Arlington, VA
I.
Desk One

Rules & Guidance

Dispatches that map a specific federal rule, piece of supervisory guidance, or examiner framework against its primary-source text. The brief is always: what does the rule actually say, and where does it depart from what came before.

Rules · 01

Model Risk Management 2026

A side-by-side reading of FIL-15-2026 against SR 11-7, mapping where the federal agencies' new model risk guidance retains, sharpens, or quietly narrows the 2011 baseline.

FIL-15-2026SR 11-712 CFR Pt. 30
Rules · 02

GENIUS Act Dashboard

A working framework for how the GENIUS Act applies to OCC-supervised stablecoin issuers — permitted issuer pathways, reserve composition, and statutory tripwires.

GENIUS ActPayment Stablecoins12 USC § 1818
Rules · 03

The Two-Track Republic

A second reading of the GENIUS Act through its defining structural choice — the dual federal and state pathways for payment stablecoin issuers, the $10B threshold that divides them, and what the bifurcation means for charter strategy.

GENIUS ActDual TrackState vs. Federal
Rules · 04

AML/CFT Program Rule Navigator

A clause-anchored walkthrough of the 2026 FinCEN and FDIC AML/CFT Program Rule proposals, grounded in the rule text itself rather than secondary commentary.

31 CFR § 1020.210FinCEN NPRMFDIC FIL
Rules · 05

UFIRS CAMELS 2026 Change Briefing

What changed in the Uniform Financial Institutions Rating System in 2026, and how examiner expectations shift in practice across the six CAMELS components.

UFIRSFFIECFIL-2026
Rules · 06

A New Way to Understand Third-Party Risk Management

A ground-up rethink of the 2023 interagency third-party risk guidance — what it left ambiguous, where the BaaS enforcement wave exposed the gaps, and what the guidance should have been.

Third-Party RiskInteragency GuidanceVendor Oversight
II.
Desk Two

Reform Trackers

Live records of regulatory and legislative reform — what each agency principal or sponsor has said on the record, what they have moved on, and where the gap between rhetoric and rule sits.

Reform · 07

The Recent White House Innovation Executive Orders

A clause-anchored reading of two recent White House executive orders shaping financial services policy — what each order directs, the agencies tasked with implementation, and the regulatory cascade downstream.

Executive ActionFederal RegisterAgency Implementation
Reform · 08

Financial System Integrity

A clause-anchored reading of the recent White House Executive Order on Financial System Integrity — what the order directs, the agencies tasked with carrying it out, and the agency releases issued in response.

Executive OrderSystem IntegrityAgency ReleasesFederal Register
Reform · 09

Bank Merger Reform Scorecard

A live scorecard of pending bank M&A reform across the FDIC, OCC, and Federal Reserve — tracking OCC threshold alignment, HHI modernization, and rural de minimis treatment.

12 CFR § 5.33HHIFDIC Statement
Reform · 10

Fed Payment Account Analysis

Analysis of the Federal Reserve's proposed Payment Account — colloquially the "skinny" master account — with a running record of Board action from Governor Waller's October 2025 framing through the May 2026 formal proposal.

Payment Account12 USC § 342Account Access
Reform · 11

Gould OCC Policy Tracker

A running record of OCC policy moves under Comptroller Gould — chartering decisions, preemption posture, supervisory letters, and licensing precedent.

OCC Bulletins12 CFR Pt. 5Licensing
Reform · 12

Global Fintech Licensing

A comparative reading of how major jurisdictions license fintechs — U.S. state MTLs and special-purpose charters set against the UK, EU/MiCA, Singapore and others — mapping where the perimeter is drawn and how passporting works.

LicensingMTLMiCACross-Border
Reform · 13

A Policy Lookahead

An experimental rulemaking calendar that triangulates what is coming from agency principals' on-the-record comments, the Federal Register, OIRA's pending review queue, and each agency's Unified Spring Agenda.

Proof of ConceptMulti-sourceForecast
Reform · 14

ABA · BPI · ICBA Position Comparison

A sourced comparison of the headline policy positions of the ABA, BPI, and ICBA — mapping where the three trade groups align (Basel capital, supervisory reform) and where ICBA's community-bank principles diverge on consolidation and the separation of banking and commerce.

Basel IIITrade GroupsJoint Letters
Reform · 15

Financial Services Bill Tracker

A live tracker of financial services legislation moving through Congress — bills by chamber and committee, sponsor and posture, and where each sits on the path from introduction to enactment.

LegislationHFSCSenate BankingBill Status
Reform · 16

The CFPB's Transformation

A running tracker of the changes remaking the Consumer Financial Protection Bureau — leadership and funding posture, rulemaking withdrawals, staffing and structural changes, and the litigation over its authority.

CFPBAgency ActionRule RollbackLitigation
Reform · 17

The Odds Digital Asset Market Structure Gets Done

A handicapping of whether digital asset market structure legislation gets enacted — the CLARITY Act's path through the Senate, the sticking points between the committees, and the odds the framework crosses the finish line this Congress.

Digital AssetsMarket StructureCLARITY ActForecast
Reform · 18

Regulatory Tracker

A live monitor that pulls activity from the federal banking agencies — and adjacent regulators — directly via API: new rules, guidance, enforcement, and notices, aggregated into a single feed as they post.

Live MonitorMulti-AgencyAPIFederal Register
III.
Desk Three

Structural Frameworks

The architecture beneath the headlines — chartering authority, preemption, agency jurisdiction, and the long arc of how U.S. banking got to its present configuration. The reference layer for every other dispatch.

Structural · 19

New Federal Reserve Supervisory Operating Principles

A look at an important pivot — Vice Chair Bowman's Statement of Supervisory Operating Principles, which redirects Federal Reserve examiners toward material financial risk and away from process, and the October 2025 → April 2026 revision arc.

Material RiskMRA / MRIAVCfS Bowman
Structural · 20

U.S. Trust Company Regulatory Framework

How state-chartered and OCC-chartered trust companies are supervised, including the CSBS Nationwide Cooperative Agreement, MTL exposure, and federal preemption posture.

12 CFR Pt. 9CSBS NCAState Law
Structural · 21

OCC Preemption Timeline

A timeline of OCC preemption authority — statute, regulation, and litigation — through the Dodd-Frank standard at 12 USC § 25b and the recent reassertions.

12 USC § 25bCuomo v. Clearing HouseCantero
Structural · 22

Regulatory Map

A working map of the federal–state supervisory architecture: who charters, who examines, who enforces, and where authority overlaps across the dual banking system.

FDICOCCFRBCSBS
Structural · 23

History of Banking

A long-arc reading of U.S. banking structure — from the First Bank of the United States through the National Bank Act, the founding of the Federal Reserve, Glass–Steagall and FDIC, to the dual-charter system today. The reference layer beneath every other dispatch.

National Bank ActFederal Reserve ActGlass–Steagall
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