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.

As the 2026 proxy season approaches, companies should be mindful of developments in required executive compensation disclosures and related issues that may arise as they prepare proxy statements. This alert surveys key developments and provides specific action items for companies to consider.