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Federal Reserve Capital Stress Testing

On October 24, the Federal Reserve Board released two proposals to update its supervisory stress testing framework, seeking comment on enhanced model transparency, disclosure processes, and proposed ...
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Adrienne A. Harris Rejoins Sullivan & Cromwell

Sullivan & Cromwell LLP announced today that Adrienne A. Harris, Superintendent of the New York State Department of Financial Services (“DFS”) from August 2021 through October 2025, has re-joined the ...
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Employer’s Failure to Require Confidentiality Agreements Leads to Dismissal of Trade Secret Claims

Sending an e-mail through this web site does not create an attorney-client relationship. You should not send us any information through this web site that you would want treated confidentially.
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New California Law Prohibits Use of “No-Rehire” Provisions in Certain Settlement Agreements

Sending an e-mail through this web site does not create an attorney-client relationship. You should not send us any information through this web site that you would want treated confidentially.
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FDIC and OCC Propose Rules to Prohibit Regulators’ Use of Reputation Risk

FDIC and OCC Issue NPR to Eliminate ‘Reputation Risk’ from Supervisory Programs ...
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FDIC and OCC Issue Proposal to Define ‘Unsafe or Unsound Practice’ and Constrain Issuance of Matters Requiring Attention

On October 7, 2025, the FDIC and the OCC jointly issued a proposal to define the term “unsafe or unsound practice” under section 8 of the FDIA (12 U.S.C. § 1818.
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Implications of the Government Shutdown on SEC Registered Securities Transactions

Summary The federal government shutdown commenced at midnight on October 1, 2025, and proposals to reopen the government failed on October 3, extending the shutdown further into the fourth quarter. On ...
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Sixth Circuit Reverses Class Certification in Major Securities Fraud Case

Sixth Circuit Clarifies Critical Issues Regarding Reliance and Damages at Class Certification in Securities Fraud Case ...
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President Trump Issues Executive Order on “Politicized or Unlawful Debanking”

President Trump signed an Executive Order titled “Guaranteeing Fair Banking for All Americans.” The Order states that “[i]t is the policy of the United States that no American should be denied access ...
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BIS Establishes 50 Percent Rule for Certain Restricted End-Users

On September 29, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an immediately effective interim final rule (referred to as the “Affiliates Rule”) which amends ...
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Sullivan & Cromwell Adds Leading Shareholder Activism Lawyers Lawrence Elbaum and Patrick Gadson

NEW YORK (APRIL 23, 2025) – Sullivan & Cromwell announced today that Lawrence Elbaum and Patrick Gadson, two preeminent shareholder activism lawyers, will join the firm April 29 as partners in its New ...
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CFTC Issues Swap Data Error Correction Notification Rules No-Action Position

On July 31, 2025, the CFTC’s Division of Market Oversight issued a letter in response to a request from industry associations regarding the CFTC’s regulations requiring swap reporting counterparties ...