Regulatory Proposals

CSBS tracks and responds to federal regulatory proposals that impact state-chartered financial institutions. The table below includes information about proposed regulations and standards and the corresponding CSBS analysis and comment letters.

Comment Deadline Sort ascending	Title	Agency	CSBS Policy/Staff Analysis	Comment Letter
05-29-2026 Filed	National Bank Non-Interest Charges and Fees	OCC	N/A	OCC IFR: National Bank Non-Interest Charges and Fees
05-18-2026 Filed	Approval Requirements for Issuance of Payment Stablecoins by Subsidiaries of FDIC-Supervised Insured Depository Institutions	FDIC	N/A	FDIC Payment Stablecoin Issuer Application Requirements
05-01-2026 Filed	Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the Office of the Comptroller of the Currency	OCC	N/A	CSBS Comment Letter: Implementing the GENIUS Act
02-11-2026 Filed	National Bank Chartering	OCC	N/A	OCC National Bank Chartering
02-06-2026 Filed	Reserve Bank Payment Account Prototype	Federal Reserve Board	N/A	Reserve Bank Payment Account Prototype
01-30-2026 Filed	Revisions to the Community Bank Leverage Ratio	OCC, Federal Reserve Board, FDIC	N/A	Regulatory Capital Rule: Revisions to the Community Bank Leverage Ratio Framework
01-29-2026 Filed	Preemption Determination: State Interest-on-Escrow Laws	OCC	N/A	OCC Preemption Determination: State Interest-on-Escrow Laws and Real Estate Lending Escrow Accounts
12-29-2025 CSBS Did Not Comment	Prohibition of Use of Reputation Risk by Regulators	FDIC, OCC	N/A	N/A
12-29-2025 Filed	Unsafe or Unsound Practices, MRAs	FDIC, OCC	N/A	Unsafe or Unsound Practices, MRAs
12-23-2025 CSBS Did Not Comment	Truth in Lending (Regulation Z); Non-application to Earned Wage Access Products	CFPB	N/A	N/A