Arthur S. Long, Parag Patel, Pia Naib and Deric Behar

Latham & Watkins Discusses Fed Revisions to Its Supervisory Rating Framework

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Key Points:

  • Under the updated framework, banks can maintain a single “deficient-1” rating across the components of capital, liquidity, and governance and controls while still being considered “well managed.”
  • Banks with a single “deficient-1” rating will no longer face activity
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Latham & Watkins Discusses Treasury Request for Public Input on GENIUS Act Implementation

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On September 19, 2025, the US Department of the Treasury (Treasury) issued an Advance Notice of Proposed Rulemaking (ANPRM), seeking public comment related to its implementation of the Guiding and Establishing National Innovation for US Stablecoins Act (the GENIUS Act), …