United States: Financial Services

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Last Spring, we provided an overview of the Texas Stock Exchange. One year later, the Exchange has clearly moved from concept to reality, following its June 27, 2026 Final Confidence Test and the launch of phased trading in July. The key question now is whether the Exchange can scale smoothly, attract listings, and build meaningful liquidity as it expands through 2026 and into 2027.

Federal banking regulators have issued new guidance addressing credit risks when lending to individuals not legally authorized to work in the United States, following a presidential executive order directing agencies to examine financial services extended to undocumented immigrants. The guidance emphasizes existing safety-and-soundness obligations while raising questions about how institutions should balance risk management with fair lending principles and access to mainstream credit.

The Federal Reserve has charted an independent course in revising anti-money laundering regulations for banks, notably excluding a key provision that would grant FinCEN oversight authority over enforcement actions. This divergence from the Treasury Department's unified regulatory approach raises critical questions about interagency coordination and the future of AML/CFT supervision. Governor Michael Barr's dissent highlights concerns about the undefined "significant or systemic" standard that will determine

The Supreme Court's landmark decisions in Trump v. Slaughter and Trump v. Cook fundamentally reshape presidential removal power over federal agency officials, overturning nine decades of precedent while carving out a narrow exception for the Federal Reserve. These rulings dramatically alter the constitutional architecture of independent agencies, with far-reaching implications for regulatory stability and the balance of power between the executive branch and federal regulators.

Is your company evaluating whether—and where—to go public? An initial public offering is a major milestone, and choosing the right listing exchange for your company requires a holistic view of regulatory requirements, market expectations, and strategic considerations across jurisdictions.

The NAIC's Financial Condition Committee has approved three significant proposals affecting insurance company risk-based capital calculations, including revised RBC factors for collateralized loan obligations and collateral loans. These changes will impact how state regulators assess insurer capital adequacy and take corrective action for weakly capitalized companies.

Minnesota has enacted legislation to license small and short-term loan arrangers while exempting certain mortgage originators and servicers from specific licensing requirements. Vermont has also passed a commercial financing licensing bill, marking significant developments in state-level financial services regulation.

The SEC's 2026 Unified Agenda reveals Chairman Atkins' regulatory priorities, including potential reforms to pay-to-play rules, expanded retail access to private markets, and clarifications to recordkeeping requirements. Will these initiatives successfully balance innovation with investor protection while reducing compliance burdens?