Federal Reserve Consultations

Key dates

2026-08-04

Federal Reserve published the proposed rule in the Federal Register at 91 FR 49526.

2026-10-05 Deadline

Public comments on the proposed rule are due.

Suggested considerations

• Compliance teams may wish to map the proposal’s threshold changes against existing Regulation O controls, including board-approval triggers, disclosure triggers, and internal lending limit checks.
• Firms may wish to identify any lending relationships that rely on current presumptions of control, especially where portfolio companies of investment fund complexes could be affected.
• Banks may wish to review insider-lending policies, forms, recordkeeping, and disclosure workflows for provisions that the proposal would codify, clarify, or remove.
• Stakeholders may wish to submit comments by 2026-10-05 if they want to influence the final treatment of thresholds, fund-complex ownership, valuation rules, or correspondent-lending provisions.
• Legal and compliance teams may wish to compare the proposed text against existing Regulation O, Regulation Y, and internal interpretive guidance to spot implementation impacts if the rule is finalized largely as proposed.

What changed

The proposal would amend 12 CFR part 215 (Regulation O) and conform related provisions in Regulation Y and other Board regulations. It would make a one-time adjustment to several dollar-based thresholds, then index those thresholds going forward based on nominal GDP. It would clarify how certain limits apply on an aggregate basis and streamline limits on loans to executive officers, including prior board-approval requirements for certain large loans.

Key dates

2026-08-04

Publication of the Federal Reserve Board notice of proposed rulemaking ‘Regulatory Modernization and Relief for Mutual Holding Companies’ in the Federal Register (91 FR 49490; FR Doc. 2026-15774) amending Regulations Q (12 CFR part 217) and MM (12 CFR part 239).

2026-10-05 Deadline

Comment deadline for submitting responses to the Federal Reserve Board on the proposed amendments to Regulations Q and MM (Docket No. R-1895; RIN 7100-AH26).

Suggested considerations

• Compliance teams at mutual holding companies and savings and loan holding companies may wish to review the proposed amendments to Regulation MM (12 CFR part 239), particularly the sections on dividend waivers, mutual-to-stock conversion processes, post-conversion restrictions, chartering requirements for subsidiary holding companies, and updated model charters and bylaws, to assess operational and governance impacts.
• Firms planning or contemplating mutual-to-stock conversions should consider comparing their current conversion documentation, use of FR MM-PS, FR MM-OC and FR MM-OF forms, and liquidation account methodologies with the proposed streamlined forms, corrected liquidation account calculations, and revised rules on stock pricing, repurchases, offers and sales, employee stock ownership plan financing and benefit plans.
• Institutions that issue, or are considering issuing, mutual capital certificates should review the proposed Appendices B and C to Regulation Q (12 CFR part 217) to evaluate whether their existing or planned instrument terms align with the model key terms for qualification as Common Equity Tier 1 or Additional Tier 1 capital, including permanence, loss-absorption, distributions and redemption features.
• Subsidiary holding companies of thrift mutual holding companies may wish to analyze the proposed elimination of the federal charter requirement and related changes to Subpart C of Regulation MM to determine chartering options, corporate structure implications, and any needed updates to organizational documents and regulatory commitments.
• Governance and legal teams at MHCs could review the proposed revisions to membership rights, proxy processes, postal mail requirements, voluntary dissolution, and the model charter and bylaws in Appendices A, C and D to Regulation MM, with a view to aligning internal policies and corporate governance frameworks with the modernized regime once finalized.
• Risk and capital management functions at bank holding companies, savings and loan holding companies and state member banks should consider evaluating capital planning assumptions and buffers in light of the clarified eligibility of mutual capital instruments as regulatory capital under Regulation Q, and identify any systems or reporting changes that may be required if the proposal is adopted.
• All affected firms may wish to prepare internal impact assessments and, where appropriate, draft comment letters addressing specific elements of Regulations Q and MM (Docket No. R-1895; RIN 7100-AH26), including any perceived risks around conflicts of interest, reduced accountability, or adjustment costs noted in the economic analysis.
• Compliance monitoring teams should plan to track the rulemaking through the comment close date and subsequent Federal Reserve actions so that, if the proposal is finalized, implementation plans can be developed for policy updates, staff training and revisions to regulatory reporting and capital instrument documentation.

What changed

The NPR proposes targeted amendments to Regulation MM (12 CFR part 239) governing mutual holding companies (MHCs), including eliminating certain dividend waiver requirements that currently apply to MHCs and their subsidiary holding companies, and revising post-conversion restrictions to reduce burdens following mutual-to-stock conversions.

Key dates

2026-07-31

Federal Reserve Board requested comment on the proposed Regulation O modernization

2026-10-05 Deadline

Expected comment deadline stated in the Federal Register notice

Suggested considerations

• Compliance teams may wish to map current insider-credit controls, approval thresholds, and disclosure workflows against the proposed higher dollar limits.
• Banks may wish to identify products and systems affected by Regulation O exceptions, including credit cards, overdraft lines, and other-purpose loans.
• Institutions may wish to review whether any existing insider or related-interest procedures depend on legacy interpretations that the proposal would codify or reorganize.
• Firms with investment fund ownership structures may wish to assess whether the proposed relief for passive interests would change current principal-shareholder or control analyses.
• Interested parties may wish to prepare comments for the Federal Register comment period once publication occurs, as the proposal states comments are due 60 days after publication.

What changed

The proposal would increase several outdated dollar-based thresholds in Regulation O, including the amounts tied to certain credit card exceptions, overdraft exceptions, executive officer loans for other purposes, and the level at which prior board approval is required. It would also establish an indexing methodology so the thresholds are automatically adjusted over time based on cumulative nominal GDP growth, reducing the need for repeated rulemaking. The Federal Reserve also says the proposal would address unnecessary applications of the rule to passive interests in companies held by...

Key dates

2026-07-31

Federal Reserve Board issued the request for comment on the proposal.

2026-08-04

Federal Register publication date referenced in the available materials.

2026-10-05 Deadline

Comment period closes 60 days after Federal Register publication, according to secondary reporting and the referenced publication timeline.

Suggested considerations

• Compliance teams may wish to review whether the institution falls within the mutual banking organization or mutual holding company framework and assess whether the proposal would affect capital planning.
• Firms may wish to evaluate existing and planned capital instruments to determine whether they could qualify as regulatory capital under the proposed clarification.
• Institutions may wish to review dividend-waiver, conversion, and other mutual-structure processes for possible operational or governance changes under the proposal.
• Affected firms may wish to prepare comment letters on capital treatment, loss-absorption, conflicts of interest, accountability, and competition effects, consistent with the issues highlighted by the Board statement.

What changed

The proposal would modernize the Board’s rules applicable to mutual banking organizations, including mutual holding companies, for the first time in about 30 years. It would clarify which instruments may count as regulatory capital, expand flexibility for certain mutual banks to raise capital, and reduce procedural burdens. The Board’s memo says the proposal would amend Regulation MM and the capital rule to address limited access to equity and costly, unclear requirements.

Key dates

2026-07-07

Federal Reserve Board issued the request for comment on the proposed AML program amendments

2026-09-05 Deadline

Indicative comment deadline if the proposal is published in the Federal Register on July 7, 2026; the Federal Reserve states comments are due 60 days after Federal Register publication

Suggested considerations

• Compliance teams may wish to review current AML/CFT program governance against the proposed minimum program components, including risk-based controls, independent testing, training, and designated accountable oversight.
• Firms may wish to map their current risk assessment methodology to the FinCEN AML priorities referenced in the proposal and identify any gaps in documentation or calibration.
• Banks may wish to assess whether resources are demonstrably weighted toward higher-risk customers, products, services, and activities, since the proposal emphasizes risk-based allocation.
• Compliance functions may wish to track the Federal Register publication date closely so the 60-day comment clock can be calculated once the notice is published.
• Commenting stakeholders may wish to compare the Federal Reserve proposal with the parallel proposals from the other agencies to identify alignment issues or operational inconsistencies.

What changed

The proposal would amend the Federal Reserve's requirements for banks to maintain anti-money laundering programs to align with parallel proposals from four other agencies. It would require banks to allocate AML resources based on risk, with greater attention to higher-risk customers and activities. It would also require banks to incorporate the Financial Crimes Enforcement Network's AML priorities into their risk assessment processes.