Alert – Volume 22 of The Bankers’ Bulletin

October 9, 2025

To our clients and friends:

We have updated our monthly Bankers’ Bulletin publication with a revised presentation format, featuring new content and additional practical tips to help banks implement the regulatory developments we cover. Today we published Volume 22, which provides our insights into key banking industry developments from September 2025, including:

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Alert – Federal Government Shutdown

October 1, 2025

To our clients and friends:

On September 30, 2025, the federal government’s funding ran out resulting in a shutdown beginning on October 1, 2025, which will continue until Congress passes and the President signs new appropriations legislation. Some federal agencies, including the Securities and Exchange Commission, are affected while others, such as federal banking regulators, will continue without (or with minimal) interruption. Our Legal Update covering certain of the impacts of the shutdown is available here.

Luse Gorman regularly advises financial institutions regarding bank regulatory and securities matters. If you have any questions about this Legal Update, please contact us. To learn more about our firm and services, please visit our website.

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Legal Update – OCC Announces Changes to Licensing Procedures and CRA Evaluations to Incorporate Debanking Reviews

September 15, 2025

On September 8, 2025, the OCC announced actions, including issuing two Bulletins, to “end the weaponization of the financial system” by “rooting out” activities that “unlawfully debank or discriminate against customers on the basis of political or religious beliefs, or lawful business activities.” Our Legal Update, available here, describes the OCC’s plan to start reviewing banks’ debanking practices in licensing application reviews and CRA evaluations, and the agency’s instructions to banks regarding responding to government information requests and preparing SAR filings. Our Legal Update also offers a number of tips for OCC-supervised institutions prepare for further scrutiny from the agency regarding this issue.

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