First 100 Days: Regulatory Update

April 8, 2025

The Senate Banking Committee advanced three key nominations on April 3.

  • Paul Atkins (Securities and Exchange Committee Chair nominee) and Jonathan Gould (nominee to serve as Comptroller of the Currency) were both reported favorably to the full Senate in a 13-11 party-line vote.
  • Luke Pettit, nominated to serve as Assistant Secretary of the Treasury, received broader bipartisan support and was reported favorably in a 19-5 vote.

The nominees could be considered on the full Senate floor as early as this week. Please see here for CREFC’s Regulatory Tracker.

Additionally, the Banking Committee will conduct a hearing on April 10 on several nominations, including one for Fed Governor Michelle Bowman for Fed Vice Chair for Supervision.

Earlier in the week, House Committee on Financial Services (HCFS) Chairman French Hill (R-AR) and members of the committee sent letters to several financial regulatory agencies requesting the rescission, modification, or re-proposal of specific Biden-Harris Administration actions. In a joint letter to the banking agencies, the lawmakers warned that the cumulative weight of recent regulatory actions “threatens to impair economic growth and the competitiveness of the U.S. financial system.” 

Specific concerns included, among others, the:
  • Federal Deposit Insurance Corp.’s climate risk guidance;
  • The Federal Reserve’s capital proposals; 
  • Consumer Financial Protection Bureau’s Section 1071 small business data rule; and 
  • SEC’s digital asset enforcement strategy.

Separately, on March 31, the OCC withdrew its participation in interagency principles for climate-related financial risk management for large financial institutions, with Acting Comptroller Rodney Hood stating that the: 

OCC’s existing guidance for banks to maintain a sound risk management framework applies to all activities conducted by supervised institutions and includes potential exposures to severe weather events or natural disasters.
A Politico article, also published on March 31, reported that “top Wall Street institutions are preparing for a severe future of global warming that blows past the temperature limits agreed to by more than 190 nations a decade ago.”

  • Reports from Morgan Stanley, JPMorgan Chase, and the Institute of International Finance (IIF) “describe how top financial institutions plan to continue operating profitably as temperatures and damages soar.”
  • The IIF report stated:
Financial institutions need to recalibrate targets to reflect that 1.5°C are no longer suitable as strategic goals. Reputational concerns may arise in the absence of an aligned view amongst stakeholders on how such processes should be handled, and what criteria may need to be applied.
Please contact Sairah Burki (sburki@crefc.org) with any questions.
 

Contact 

Sairah Burki
Managing Director,
Head of Regulatory Affairs and Sustainability
703.201.4294
sburki@crefc.org
The information provided herein is general in nature and for educational purposes only. CRE Finance Council makes no representations as to the accuracy, completeness, timeliness, validity, usefulness, or suitability of the information provided. The information should not be relied upon or interpreted as legal, financial, tax, accounting, investment, commercial or other advice, and CRE Finance Council disclaims all liability for any such reliance. © 2025 CRE Finance Council. All rights reserved.

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