Citing the widespread use of these voluntary filings and concern regarding the use of SEC processes for unintended purposes, on Friday, January 23, the SEC Staff updated its long-standing policy and ...

Christopher Viapiano is a partner in Sullivan & Cromwell’s Litigation Group, Co-Head of the Firm’s Securities Litigation Practice and a member of the Criminal Defense & Investigations Group. Mr.

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Sending an e-mail through this web site does not create an attorney-client relationship. You should not send us any information through this web site that you would want treated confidentially.

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 ...

President Trump signed an Executive Order titled “Guaranteeing Fair Banking for All Americans.” The Order states that “[i]t is the policy of the United States that no American should be denied access ...

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, ...

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 ...

Following the Supreme Court’s decision last summer in SEC v. Jarkesy, former directors of a national bank challenged the OCC’s authority to seek civil money penalties in an administrative proceeding ...

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

The SEC Division of Corporation Finance announced that it will not respond to no-action requests for the exclusion of Rule 14a-8 shareholder proposals, other than no-action requests to exclude a ...