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 …

Sullivan & Cromwell Discusses Acting FDIC Chairman’s Preview of Changes to Resolution Planning and Execution

On October 15, Travis Hill, Acting Chairman of the Federal Deposit Insurance Corporation (who has been nominated to permanently lead the agency) delivered a speech titled “Resolution Readiness and Lessons Learned from Recent Large Bank Failures” at the EU Single …

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 …

Sullivan & Cromwell Discusses Banking Agencies’ Request for Information About Bank Relationships with Fintechs

On July 25, 2024, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency (together, the “Agencies”) issued a request for information (the “RFI”)[1] regarding arrangements …