This Week in Finance — Washington (#36, 2026)

Expanded US exam cycle for small banks; SEC extends LCH SA clearing exemptions; FINRA outside activity rule approved; interagency third-party risk guidance unveiled; LCH SA CDSClear fund rule approved.

This Week in Finance — Washington (#36, 2026)

September 13, 2026 to September 19, 2026

This is Queen Street Analytics' weekly digest of regulatory developments, legislative discussions and other government-related news for professionals in the financial industry, banking, credit unions, insurance, payment processing, fintech, credit card issuing, asset management, venture capital, private equity, and crypto-currencies. Once a week, we break down the most important updates in this space in under five minutes.

Want to track other GR news in adjacent industries? Don’t miss this week’s updates in ICT & Cybersecurity. Also consider subscribing to our Finance - Ottawa edition covering critical GR news north of the border.

📋 In This Week's Newsletter

• 🇺🇸 Federal Government News
• 📚 What We're Reading This Week


Federal Government News

Expanded Examination Cycle for Small Insured Depository Institutions and Foreign Bank Branches

The Office of the Comptroller of the Currency, Federal Reserve Board, and FDIC jointly issued an interim final rule implementing section 903 of the 21st Century ROAD to Housing Act. The rule raises the asset threshold for supervised institutions to qualify for an 18-month on-site examination cycle to $6 billion, up from the previous $3 billion threshold. Parallel changes apply to U.S. branches and agencies of foreign banks, consistent with the International Banking Act. The rule is effective September 14, 2026. Qualifying institutions must be well-capitalized, well-managed, not subject to enforcement orders, and have no recent change in control. The agencies estimate approximately 188 additional institutions will become eligible for the extended cycle, including 19 U.S. branches/agencies of foreign banks, bringing the total eligible to about 4,016. Comments are invited by October 14, 2026.

Sources: www.federalregister.gov
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Self-Regulatory Organizations; LCH SA Granted Conditional Exemptive Relief for RepoClear

The Securities and Exchange Commission granted conditional exemptive relief to LCH SA under section 36 of the Securities Exchange Act regarding certain rule filing requirements relevant to its RepoClear service. The order allows LCH SA to file rule changes related to RepoClear with U.S. Clearing Members under the expedited process specified in section 19(b)(3)(A) and Rule 19b-4(f)(6), provided those changes do not significantly affect CDSClear operations. The relief is contingent upon LCH SA providing certain notifications and ceases if U.S. Clearing Members are no longer present. U.S. Clearing Members will have opportunities to review and comment on rule changes, and the Commission retains authority to suspend filings if necessary.

Sources: www.federalregister.gov

SEC Approves FINRA Rule 3290 on Outside Activities

The SEC approved FINRA Rule 3290, replacing prior Rules 3270 and 3280 on outside activities of associated persons. The rule requires registered persons to report investment-related outside activities and associated persons to report outside securities transactions. Member firms must assess the risks of these activities, may impose restrictions or prohibitions, and are obligated to supervise compliance with any imposed restrictions. Certain activities, such as personal investments in non-securities or specified real estate transactions, are excluded from the scope. Activities at unaffiliated registered investment advisers are treated as outside activities without direct member supervision. The rule also prescribes recordkeeping obligations and allows for exemptions via the FINRA Rule 9600 Series.

Sources: www.federalregister.gov

Interagency Proposed Guidance on Third-Party Risk Management

The OCC, Federal Reserve, FDIC, and NCUA released proposed interagency guidance addressing third-party risk management for banking organizations. The guidance is designed to reflect supervisory experience and encourages a risk-based approach, including identifying, assessing, and overseeing risks, making informed decisions on residual risk, and implementing governance practices. It replaces the 2023 Guidance, emphasizing tailored oversight based on relationship risk level, organization size, and complexity. Public comments are invited by November 16, 2026. The guidance clarifies expectations on subcontractor oversight, co-ventures, consortia, and the use of insurance and resilience planning. The agencies state that criticism during examinations will be specific to the institution's actual operations.

Sources: www.federalregister.gov

SEC Approves LCH SA CDSClear Trade Registration Fund Rule

The SEC approved LCH SA's proposed rule change to establish a Trade Registration Fund (TRF) for its CDSClear business. The TRF introduces margin forbearance by allowing eligible members to temporarily register new trades even if there is insufficient posted collateral, provided reserves from the TRF are available. The TRF is funded separately from the CDS Default Fund, with member contributions based on utilization. LCH SA retains discretion to require additional collateral at any time and sets limits on usage. Additional amendments update internal credit scoring, credit reviews, and monitoring of exposures for Guaranteed Sponsored Members.

Sources: www.federalregister.gov
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What We're Reading This Week

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