Market Intelligence

On October 22, 2026, the US Department of the Treasury released a notice of proposed rulemaking (Proposed Rule), to implement the Comprehensive Outbound Investment National Security Act of 2025 (COINS Act), which Congress enacted on December 18, 2025. The Proposed Rule would significantly expand the existing Outbound Investment Security Program (OISP) rules, which have been in effect since January 2, 2025, and appear at 31 C.F.R. Part 850 (Part 850). The Proposed Rule would create a new Part 851, and Part 850 would continue to govern activity until the final Part 851 regulations take effect. Comments are due December 7, 2026, and the COINS Act directs Treasury to issue final regulations by March 13, 2027.

The Office of the Comptroller of the Currency released a comprehensive report examining whether the nine largest U.S. national banks engaged in "debanking" practices that restricted financial services access based on customers' political or religious beliefs or lawful business activities. The report concluded that broad reputation risk policies lacking clear standards may have limited access to banking services for certain individuals and entities, prompting the OCC to announce new policy measures and poten

The Office of the Comptroller of the Currency has released its final report examining potential debanking practices at the nation's nine largest banks, revealing how broad reputation-risk policies may have disadvantaged customers based on their political, religious, or social views. The report details findings from a supervisory review covering January 2020 through September 2025 and outlines steps banks have taken to address fair-access concerns.

The Consumer Financial Protection Bureau has launched a new initiative to investigate potentially unlawful debanking practices at large financial institutions, following an OCC report that identified policies denying or restricting customers' access to financial services based on political or religious beliefs or participation in lawful business activities.

Private credit has exploded over the past decade, providing borrowers with an increasingly important source of capital and investors with access to attractive yields. But as the market has expanded, so too has the potential for significant disputes when borrowers encounter financial distress, collateral proves insufficient or unreliable, or lenders discover that the information on which they relied does not reflect the underlying reality. This article examines the forensic anatomy of private credit disputes

On October 22, 2026, the U.S. Department of the Treasury (“Treasury”) issued a Notice of Proposed Rulemaking (“NPRM”) setting forth a proposed rule to implement the Comprehensive Outbound Investment National Security Act of 2025 (“COINS Act”).