
Episode #243
Regulators find no shortcomings in any of 15 big bank resolution plans | Sep 30
In this episode: 1. Regulators find no shortcomings in any of 15 big bank resolution plans 2. Treasury finalizes rule for state stablecoin certification reviews 3. OFAC designates 46 Sinaloa Cartel targets Transcript Today: Regulators find no shortcomings in any of 15 big bank resolution plans. Plus, Treasury finalizes rule for state stablecoin certification reviews. And, OFAC designates 46 Sinaloa Cartel targets. Alex here. This is LexRegPulse Daily for Wednesday, September 30, 2026. First, the Fed and FDIC cleared all 15 living wills filed last October by the largest banking organizations. No shortcomings. No deficiencies. Across the board. BNP Paribas also closed out a shortcoming flagged back in its 2021 plan. That means none of the 15 firms carries a formal finding into its next resolution plan. Five firms got individual letters: American Express, Barclays, BNP Paribas, Deutsche Bank and UBS. The other ten received a shared template crediting meaningful improvements, including Royal Bank of Canada's shift to a multiple-point-of-entry U.S. strategy. American Express is the exception worth watching. No shortcoming, but regulators flagged significant uncertainty in its preferred sale strategy β one buyer purchasing its bank, operating company and parent simultaneously, across both an FDIC receivership and a Chapter 11 case. The FDIC generally won't accept contingent bids, and it must pick the least costly option. Amex needs a new approach before its 2028 plan. Second, Treasury's Stablecoin Certification Review Committee filed the rulebook for reviewing state stablecoin regimes, publishing today as an interim final rule. Under the GENIUS Act, state-qualified issuers with ten billion dollars or less outstanding can only choose a state regulator once their state's regime is certified as substantially similar to federal standards. Treasury isn't one of the primary federal stablecoin regulators, so this filing doesn't pull forward the Act's January 2027 effective date. The Fed's own GENIUS proposals now carry a firm deadline β comments close November 30. Two provisions deserve a close read: issuer capital requirements indexed to nominal GDP growth, and a tying prohibition reaching every permitted stablecoin issuer, not just the ones the Board directly supervises. Third, OFAC designated 46 Sinaloa Cartel targets Tuesday, 21 individuals and 25 entities, including cartel leader Ismael Zambada Sicairos and Tijuana cell leaders. Banks with border-region retail business or Mexican correspondent relationships carry direct exposure, and blocking obligations attach immediately upon designation. Separately, under Operation Economic Outcast, OFAC designated 10 more individuals and entities for procuring weapons components for Iran's defense ministry β a risk for trade-finance and correspondent books touching third-country intermediaries. Fourth, the Financial Stability Oversight Council met Tuesday and found the financial system resilient, though its Household Resilience Working Group flagged fraud as a persistent, growing concern. The Fed, OCC and FDIC also briefed the Council on their rules simplifying supervision. Separately, Vice Chair for Supervision Michelle Bowman told community bankers that ransomware, business email compromise and AI-assisted attacks are already hitting smaller institutions, and committed to tailoring cyber exams to their risk profiles. Governor Christopher Waller, at Sibos, distinguished agent-assisted commerce from agent-delegated commerce and said large language models could strengthen sanctions screening and anti-money-laundering systems. Morgan here with your market minute. Futures as of 6:25 AM Eastern. S and P futures at 7,737, up 0.06 percent. Nasdaq futures at 30,594, down 0.06 percent. Dow futures at 51,756, up 0.10 percent. The ten-year yield at 5.25 percent, up 2 basis points. Crude at 90.37, up 1.11 percent. Bitcoin at $83,767, up 0.17 percent. SOFR at 3.9 percent, up 0 basis points. High Yield at 3.02 percent, up 9 basis points. For the full analysis, including today's one read on clean living-will results, check your LexRegPulse daily briefing in your inbox, or catch LexRegPulse Weekly every Sunday. I'm Alex. This has been LexRegPulse Daily. --- Your daily 5-minute briefing on banking regulations, compliance updates, and enforcement actions. Stay compliant, stay informed with LexRegPulse Daily. Written edition: https://lexregpulse.com/brief/2026-09-30 Cite as: LexRegPulse Daily Brief, 2026-09-30. Every bullet on the edition page has a stable link (#b-1, #b-2 β¦). Get the brief by email, free, every morning at 6:45 AM ET: https://lexregpulse.com/subscribe

