On October 7, 2025, the FDIC and the OCC jointly issued a proposal to define the term “unsafe or unsound practice” under section 8 of the FDIA (12 U.S.C. § 1818.

On October 24, the Federal Reserve Board released two proposals to update its supervisory stress testing framework, seeking comment on enhanced model transparency, disclosure processes, and proposed ...

Revised Policy Would Enable Greater Scope for Digital Asset-Related Activities by Uninsured State Member Banks ...

New York +1-212-558-3121 giuffrar@sullcrom.com ...

LONDON (SEPTEMBER 1, 2025) – Sullivan & Cromwell LLP announced today the next step forward in its global strategic plan to enhance and expand its private capital, restructuring and leveraged finance ...

In 2009, former Chief Counsel for the Internal Revenue Service Donald L. Korb joined Sullivan & Cromwell as a partner and at that time, became the head of the Firm’s Tax Controversy Practice. A ...

Renata Hesse is Co-Head of the Firm’s Antitrust Group. Her practice focuses on antitrust counseling, cartels and merger clearance. Ms. Hesse is frequently recognized as a leading and influential ...

New York +1-212-558-4000 banderj@sullcrom.com ...

FDIC and OCC Issue NPR to Eliminate ‘Reputation Risk’ from Supervisory Programs ...

Summary The federal government shutdown commenced at midnight on October 1, 2025, and proposals to reopen the government failed on October 3, extending the shutdown further into the fourth quarter. On ...

On September 29, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an immediately effective interim final rule (referred to as the “Affiliates Rule”) which amends ...

For more information on these and other developments, we encourage you to reach out to your regular Sullivan & Cromwell contact. Highlights In this issue, we discuss key developments in Q3 2025, ...