Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 24 NOVEMBER 2025

Changes On The Horizon For Recovery And Resolution Planning

Moore & Van Allen, PLLC
Moore & Van Allen, PLLC
Contributor
Moore & Van Allen, PLLC

Moore & Van Allen, PLLC

At Moore & Van Allen, representation extends beyond traditional legal services. We represent ideas,...

View firm profile
Explore more from Moore & Van Allen, PLLC

The banking industry is on the cusp of more changes in recovery and resolution planning, shaped by shifting regulatory priorities and perspectives on the 2023 regional bank failures.

United StatesFinance and Banking
Kathryn Wellman
Kathryn Wellman
Emily Clayton
Emily Clayton

The banking industry is on the cusp of more changes in recovery and resolution planning, shaped by shifting regulatory priorities and perspectives on the 2023 regional bank failures. Recent actions by the FDIC and OCC have previewed a rollback of enhanced requirements introduced just last year—moves that would reduce the documentation required from large institutions. This article summarizes the proposed changes and potential impacts.

Why Regulators Are Changing Course

The 2023 regional bank failures raised questions about resolution readiness, prompting regulators to strengthen rules in 2024. The FDIC revised its resolution planning rule effective October 2024, and the OCC updated its recovery planning guidelines effective January 2025. These changes applied recovery and resolution planning standards to a broader range of banks, increased the frequency of submissions, and added more detailed content requirements.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

SEC Advances “Responsible Retailization” Through A Potential Accredited Investor Exam And Potential Regulated Fund Reforms

On September 30, 2026, the Securities and Exchange Commission (SEC) issued two rule proposals and five notices aimed at expanding investors’ access to private markets. The package would add ways to qualify as an accredited investor, including passing a new exam administered by the Financial Industry Regulatory Authority (FINRA), broaden performance-based compensation and modernize regulated funds, including interval funds and business development companies (BDCs).
United StatesFinance and Banking
Proskauer Rose LLP
Proskauer Rose LLP
Article

SEC Proposes Rule Amendments To Expand Retail Access To Private Markets

The SEC has proposed sweeping amendments to expand retail investor access to private market strategies, including changes to performance-based compensation rules for registered investment advisers and modernization of the interval fund framework. The proposals also explore new credential-based pathways for individuals to qualify as accredited investors, potentially opening private offerings to a broader pool of eligible participants.
United StatesFinance and Banking
Duane Morris LLP
Duane Morris LLP
Article

New NYSE Delisting Rules: What Microcap Companies Need To Know About The $0.25 Minimum Trading Price

The SEC has approved new NYSE and NYSE American listing rules establishing a $0.25 minimum trading price, effective July 1, 2027. A single closing price below this threshold triggers immediate trading suspension and delisting proceedings with no cure period. Companies trading at low share prices must act now during the transition period to implement reverse stock splits and establish monitoring procedures before this hard floor takes effect.
United StatesFinance and Banking
Bevilacqua
Bevilacqua
Article

SEC Approves FINRA’s New “Outside Activities” Rule

The Securities and Exchange Commission has approved FINRA Rule 3290, which will replace existing rules governing outside business activities and private securities transactions for registered persons. This new rule narrows the scope to focus on investment-related activities while maintaining similar supervisory obligations for member firms. Understanding the key changes and implementation requirements will be critical for broker-dealers as they update their compliance policies and procedures.
United StatesFinance and Banking
WilmerHale
WilmerHale
Article

The Financing Problem Behind the AI Infrastructure Boom: What Lenders and Sponsors Need to Watch

As AI infrastructure spending surges toward $697 billion in 2026, hyperscalers and compute providers are increasingly turning to debt, structured financing, and GPU-backed collateral to fund expansion. While demand projections remain bullish, a critical timing gap is emerging between capital deployment and cash flow generation, creating significant risks for lenders, sponsors, and operators across the ecosystem.
United StatesFinance and Banking
Riveron
Riveron
Article

The Desk: July Edition

The CFTC continues its regulatory evolution with significant developments in June 2026, including the rescission of its longstanding no-deny settlement policy, proposed amendments to whistleblower protections, and joint harmonization efforts with the SEC on data reporting and portfolio margining. The agency also advances its oversight of prediction markets while CME Group challenges the CFTC's characterization of cryptocurrency perpetual futures contracts.
United StatesFinance and Banking
Moore & Van Allen, PLLC
Moore & Van Allen, PLLC
Article

Capital Recalibration: Overview Of The 2026 Basel III, Revised Standardized Approach, And GSIB Surcharge Proposals

In March 2026, U.S. banking regulators released a comprehensive set of proposals to recalibrate capital requirements for banking organizations of all sizes, marking a significant shift from their 2023 approach. These proposals aim to enhance risk sensitivity, reduce complexity, and produce more moderate capital impacts while improving the competitive position of U.S. banks relative to their international peers. The proposals include implementing final Basel III standards for the largest banks, revising the
United StatesFinance and Banking
Moore & Van Allen, PLLC
Moore & Van Allen, PLLC
Article

Client Alert: USCIS Reaches Fiscal Year 2027 H-1B Cap

U.S. Citizenship and Immigration Services has announced that it has received sufficient H-1B petitions to meet both the 65,000 regular cap and the 20,000 master's cap for fiscal year 2027, confirming no additional selection rounds will be conducted. Employers and employees whose registrations were not selected should review current immigration status and explore alternative work authorization options before expiration dates approach.
United StatesImmigration
Moore & Van Allen, PLLC
Moore & Van Allen, PLLC
Article

The Desk: October Edition Newsletters

The October edition of The Desk covers critical developments in derivatives regulation, including the approaching Treasury clearing compliance deadline, CFTC enforcement actions totaling over $150 million in penalties, and new guidance on tokenized assets and prediction markets. The newsletter examines how regulatory agencies are adapting to digital innovation while maintaining market integrity through enhanced whistleblower programs and stricter oversight of commodity pool operators.
United StatesFinance and Banking
Moore & Van Allen, PLLC
Moore & Van Allen, PLLC
Article

Recent Developments In U.S. Immigration Policy

The U.S. Department of Homeland Security has proposed a dramatic new fee structure that would add over $100,000 to the cost of filing certain H-1B visa petitions. This proposed rule could fundamentally reshape employer-sponsored immigration by generating an estimated $8.8 billion annually while significantly increasing the financial burden on companies seeking to hire foreign workers under the H-1B cap. Employers and stakeholders have until September 24, 2026...
United StatesImmigration
Moore & Van Allen, PLLC
Moore & Van Allen, PLLC
Article

Can The CFTC Provide Clarity? The CFTC's Anticipated Regulation CTX And Regulation CAM

The Commodity Futures Trading Commission has released an advance notice of proposed rulemaking that could fundamentally reshape how retail crypto asset transactions are regulated in the United States. Through two proposed frameworks—Regulation CTX and Regulation CAM—the CFTC aims to establish comprehensive oversight of crypto exchanges and leveraged digital asset trading, potentially bringing state-licensed platforms under federal jurisdiction.
United StatesFinance and Banking
Moore & Van Allen, PLLC
Moore & Van Allen, PLLC