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ARTICLE · 10 AUGUST 2026

Federal Reserve And FDIC Propose Long-awaited Regulation O Modernization

Hogan Lovells Cadwalader
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The Federal Reserve Board and FDIC have proposed comprehensive updates to Regulation O, which governs lending to bank insiders. These modernization efforts would quadruple key dollar thresholds unchanged since the 1970s, address complications arising from investment fund ownership structures, and incorporate statutory changes from the Dodd-Frank Act while maintaining core protections against preferential lending and insider abuse.

United StatesFinance and Banking
Daniel Meade
Daniel Meade
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The Federal Reserve Board (“FRB”) and Federal Deposit Insurance Corporation (“FDIC”) have issued complementary proposals to modernize the rules governing extensions of credit to bank insiders.

Regulation O generally limits and imposes procedural requirements on loans by a bank to its executive officers, directors, principal shareholders and their related interests. Although Congress enacted these restrictions to prevent preferential lending and insider abuse, the FRB has not comprehensively updated Regulation O since 1979. The proposals would retain the regulation’s principal safeguards while updating dollar thresholds, addressing its sometimes incongruous application to investment-fund portfolio companies and incorporating intervening statutory changes.

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