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.

The S&C Tariffs Tracker summarizes the status of various tariffs and trade measures that the Trump administration has announced, is implementing, or is actively considering for implementation. S&C ...

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

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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 ...

n a speech delivered at the 25th anniversary gala for the University of Delaware’s Weinberg Center for Corporate Governance on October 9, the Chair of the SEC, Paul Atkins, stated that “ [t]he view ...

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In a Decision that Turned on Market Definition, the U.S. District Court for the District of Columbia Ruled that the FTC Failed to Prove that Meta Illegally Maintained a Monopoly ...

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 ...

Acting FDIC Chairman Hill Offers Lessons Learned from 2023 Bank Failures and Discusses Potential Streamlining of Resolution Plan Requirements and Improvements to ...

Frank H. Golay, Jr. was a Partner of Sullivan & Cromwell from 1985 to 2008. His practice included numerous securities offerings, merger and acquisition transactions and general corporate advice. He ...

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, ...