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Welcome to Goodwin’s Financial Services News Roundup. Our newsletter highlights important legal, regulatory, and business developments related to financial services and banking.
In this issue
- CFPB Narrows Small Business Lending Rule
- Federal Banking Agencies Issue Updated Host State Loan-to-Deposit Ratios
- OCC Releases Spring 2026 Semiannual Risk Perspective, Addressing Key Risks in Federal Banking System
- Anchor Bank Assumes Deposits of Community Bank and Trust - West Georgia in Receivership
1CFPB Narrows Small Business Lending Rule
On May 1, the Consumer Financial Protection Bureau (CFPB) issued a final rule amending the small business lending rule under Regulation B, which implements ECOA, as amended by section 1071 of the Dodd-Frank Act. Section 1071 requires the CFPB to adopt rules governing the collection of certain data on credit applications for women-owned, minority-owned, and small businesses. The final rule amends a prior version of the small business lending rule finalized in 2023 by narrowing the scope of covered credit transactions (now excluding merchant cash advances, agricultural lending, and small dollar loans of $1,000 or less), covered financial institutions (now excluding Farm Credit System lenders and raising the origination threshold from 100 to 1,000 covered credit transactions), small business (decreasing gross annual revenue threshold from $5 million or less to $1 million or less), and relevant data points (now focusing on “core” data points). The CFPB indicated it may consider further amendments. This final rule takes effect on June 30, 2026, with compliance required by January 1, 2028.
2Federal Banking Agencies Issue Updated Host State Loan-to-Deposit Ratios
On May 1, the Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), and Board of Governors of the Federal Reserve System (Federal Reserve) jointly issued their annual update to host state loan-to-deposit ratios, which serve as benchmarks for assessing a bank’s compliance with the prohibition against deposit production offices in section 109 of the Riegle-Neal Interstate Banking and Branching Efficiency Act of 1994. These ratios measure total loans relative to total deposits in each state and are used to help determine whether banks operating interstate branches are adequately meeting local credit needs.
3OCC Releases Spring 2026 Semiannual Risk Perspective, Addressing Key Risks in Federal Banking System
On May 7, the OCC released its Semiannual Risk Perspective for Spring 2026, reporting on key issues facing the federal banking system. On credit risk, the OCC flagged ongoing “headwinds” facing several types of commercial real estate, including refinancing risk; potential weakness in private credit markets warranting monitoring of borrower performance and refinancing risk; and an increase in past-due consumer loans. Among compliance and operational risks, the OCC highlighted cybersecurity, fraud, and BSA/AML compliance risks, including in light of evolving geopolitical tensions and artificial intelligence. The report includes additional details about these and other risks.
4Anchor Bank Assumes Deposits of Community Bank and Trust - West Georgia in Receivership
On May 1, the FDIC announced the closure and receivership of Community Bank and Trust - West Georgia (Community Bank). Substantially all insured deposits were assumed and certain assets acquired by Anchor Bank, including all three branches of Community Bank. Although approximately $27 million of the $268 million of total deposits held by Community Bank exceeded FDIC insurance limits, the FDIC announced that it may later make payments to uninsured depositors based on recoveries from the sale of Community Bank’s assets. The FDIC estimates that Community Bank’s failure will cost the Deposit Insurance Fund approximately $97 million.
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Horizon Scan for Private Investment Funds: Recent Developments and What to Look Out For (May 2026)
This horizon scan highlights the principal legal and regulatory developments (excluding tax) that European managers should monitor over the coming months. In our full analysis, we have grouped topics under headings, commented on issues we think are especially noteworthy, and included a note, highlighted in red, for each topic to indicate any new topics or material updates since the previous edition of our horizon scan (published in February 2026). We have set out below headline points on recent developments that we would flag, followed by three overarching themes that emerge from the developments covered in this horizon scan. To read more, click here.
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