Sullivan & Cromwell Discusses Warnings to Bank CEOs About Cybersecurity Risks of Anthropic’s New AI Model

On April 7, 2026, Treasury Secretary Scott Bessent and Federal Reserve Chair Jerome Powell convened an urgent, closed-door meeting with the CEOs of some of the nation’s largest banks to discuss the cybersecurity risks posed by Anthropic’s newly announced AI …

Sullivan & Cromwell Discusses Proposed FSOC Changes to Nonbank SIFI Designation Guidance

On March 25, 2026, the Financial Stability Oversight Council (the “Council”) unanimously voted to propose amendments to its interpretive guidance (the “Proposed Interpretive Guidance”) regarding the designation of nonbank financial companies as “systemically important financial institutions” (“SIFIs”) for supervision by …

Davis Polk Discusses Federal Banking Agency Guidance on Capital Treatment of Tokenized Securities

Banking organizations must ensure that a tokenized security confers identical legal rights as its non-tokenized counterpart to qualify for the same capital treatment as the non-tokenized form of the security, according to new guidance from the federal banking agencies.

Overview

Simpson Thacher Discusses New Fed Principles to Shift Bank Supervisory Priorities

On November 18, 2025, the Federal Reserve released a Statement of Supervisory Operating Principles that sets out changes to how Federal Reserve examiners should supervise banking organizations. The Statement translates Vice Chair for Supervision Michelle Bowman’s stated priorities into concrete …

How to Improve the Bank Charter Application Process

New bank formation in the United States is at an all-time low, and Americans increasingly rely on non-bank financial technology companies (fintechs) to satisfy their financial services needs. Fintechs that do not operate through banks mostly operate outside the direct …