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 ...

The S&C Tariffs Tracker summarizes the status of various tariffs and trade measures that the Trump administration has announced, is implementing, or is actively considering for implementation. S&C ...

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.

The Sixth Circuit overturned a discovery order against FirstEnergy, reaffirming that internal investigations led by outside counsel are protected by attorney-client privilege. Sullivan & Cromwell ...

FDIC and OCC Issue NPR to Eliminate ‘Reputation Risk’ from Supervisory Programs ...

IRS Announces Intent to Partially Withdraw Previously Proposed Regulations and Provides Interim Guidance Including Revised Rules Governing Domestic Transactions, Troubled Companies and Acquiring ...

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 ...

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 ...

Following the Supreme Court’s decision last summer in SEC v. Jarkesy, former directors of a national bank challenged the OCC’s authority to seek civil money penalties in an administrative proceeding ...

LONDON (SEPTEMBER 1, 2025) – Sullivan & Cromwell LLP announced today the next step forward in its global strategic plan to enhance and expand its private capital, restructuring and leveraged finance ...

Sixth Circuit Clarifies Critical Issues Regarding Reliance and Damages at Class Certification in Securities Fraud Case ...

In a closely watched appeal that will have significant implications for corporate internal investigations, Sullivan & Cromwell won a stay of a federal court order that threatened to undermine the ...