Yesterday, the U.S. Court of Appeals for the Ninth Circuit issued a one-page order granting an injunction pending appeal sought by a coalition led by the U.S. Chamber of Commerce, temporarily halting ...

Mamdani’s key campaign proposals to impose a City personal income tax surcharge and raise the State corporate tax rate would require State legislation. Potential changes to City corporate tax and UBT ...

On October 7, 2025, the FDIC and the OCC jointly issued a proposal to define the term “unsafe or unsound practice” under section 8 of the FDIA (12 U.S.C. § 1818.

FDIC and OCC Issue NPR to Eliminate ‘Reputation Risk’ from Supervisory Programs ...

President Trump signed an Executive Order titled “Guaranteeing Fair Banking for All Americans.” The Order states that “[i]t is the policy of the United States that no American should be denied access ...

For more information on these and other developments, we encourage you to reach out to your regular Sullivan & Cromwell contact. Highlights In this issue, we discuss key developments in Q3 2025, ...

On September 29, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an immediately effective interim final rule (referred to as the “Affiliates Rule”) which amends ...

Sixth Circuit Clarifies Critical Issues Regarding Reliance and Damages at Class Certification in Securities Fraud Case ...

Summary The federal government shutdown commenced at midnight on October 1, 2025, and proposals to reopen the government failed on October 3, extending the shutdown further into the fourth quarter. On ...

On October 24, the Federal Reserve Board released two proposals to update its supervisory stress testing framework, seeking comment on enhanced model transparency, disclosure processes, and proposed ...

IRS Announces Intent to Partially Withdraw Previously Proposed Regulations and Provides Interim Guidance Including Revised Rules Governing Domestic Transactions, Troubled Companies and Acquiring ...

Sullivan & Cromwell LLP announced today that Adrienne A. Harris, Superintendent of the New York State Department of Financial Services (“DFS”) from August 2021 through October 2025, has re-joined the ...