On September 17, 2025, the Securities and Exchange Commission (SEC or the Commission) released a policy statement (the Policy Statement) addressing its approach to mandatory arbitration provisions in the governing documents of companies intending to go public (each, an Issuer).

On 15 July 2025, the Financial Conduct Authority (FCA) released Policy Statement PS25/9, confirming the final rules under the Public Offers and Admission to Trading Regulations 2024 (POATRs). These reforms overhaul the UK’s prospectus regime, replacing the retained EU Prospectus Regulation and taking effect from 19 January 2026. The new framework aims to simplify capital raising, reduce costs for issuers and enhance the UK’s competitiveness as a listing venue. 

The FCA’s reforms are part of a broader government strategy to ensure regulation is targeted, proportionate and growth-oriented. They follow extensive consultation, including CP24/12 and CP25/2, and reflect recommendations from Lord Hill’s UK Listing Review and the Secondary Capital Raising Review.

In this alert, Winston’s Financial Services Industry Group examines recent developments in debanking, focusing on two new OCC bulletins that clarify regulatory expectations. While these bulletins provide new insight into how the OCC is addressing debanking under the current administration, they also leave several important questions unanswered.

The OCC’s first bulletin addresses how politicized or unlawful debanking will factor into licensing applications and Community Reinvestment Act evaluations, emphasizing the importance of fair access and treatment. The second bulletin reminds banks of their obligations under the Right to Financial Privacy Act, particularly in light of recent congressional scrutiny, and underscores the need to protect customer financial records unless disclosure is legally required.

What does this mean for you?