Federal Reserve Board Proposes Update to Regulation O

On August 25, 2026, Cravath prepared a memo for its clients entitled “Federal Reserve Board Proposes Update to Regulation O.” The memo discusses the Federal Reserve Board’s request for comments on a proposed rulemaking to modernize Regulation O, which establishes limits on lending by a bank to individuals and entities that can potentially influence its lending decisions, as well as related governance and recordkeeping requirements for insider lending. 

The memo also discusses a parallel action by the Federal Deposit Insurance Corporation requesting comments on a proposed rulemaking that would raise and index the insider lending thresholds for FDIC‑supervised institutions to align with the Board’s Regulation O proposal.

Please click here to read the memo.