On December 5, 2025, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) issued a joint statement (the Statement) rescinding the Interagency Guidance on Leveraged Lending, issued March 2013 (the 2013 Guidance), as well as the Frequently Asked Questions for Implementing March 2013 Interagency Guidance on Leveraged Lending, issued February 2014 (the 2014 FAQs). The Federal Reserve, which co-signed both documents, has not yet indicated whether it will follow suit, but one would expect larger state-chartered banks that are members of the Federal Reserve System (and thus supervised by the Federal Reserve) to lobby the Federal Reserve for equal treatment on this important issue to maintain a level playing field with their national bank and state-chartered, FDIC-supervised bank competitors.

The Reg E Reader features insights from Winston & Strawn’s multidisciplinary Consumer Financial Services Group on legal and enforcement developments related to Regulation E. The blog provides guidance and best practices for those who must remain compliant with the complex, evolving requirements of the regulation. In this blog post, Caitlin Mandel, Arman Aboutorabi, and Sydney Alexandra Rose provide a year-end review on the status of the CFPB, highlighting recent news, rulemaking activities, and hints toward the agency's future heading into 2026.